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United 
Environmental Protection 
Agency % 


Office of Pollution 
Prevention and Toxics 
Washington, DC 20460 


EPA 742-R-97-00 
June 1997 


Pollution Prevention 1997 

A National Progress Report 


100% recycled paper (50% post-consumer) 










In a work of this magnitude, a disclaimer is necessary: There is a lot of good prevention 
work we could have highlighted here and have not for lack of space. In no way does our 
failure to mention any project imply that we do not value its contributions to environmental 
protection. Likewise, mention of programs, products, services, and organizations in this 
publication does not imply approval or endorsement by the EPA. 

Copies of this report are available from EPA’s Pollution Prevention Information Clearing¬ 
house. Comments on the report are welcome. Readers can direct their comments to the 
Clearinghouse at: 

401 M St., SW (7409) 

Washington, DC 20460 
Phone:202-260-1023 
Fax: 202-260-4659 
E-mail: ppic@epamail.epa.gov 




Table of Contents 



Executive Summary 


1 


Chapter 1 — Promoting Prevention at EPA 


15 


EPA Perspectives on Pollution Prevention by Lynn Goldman, Assistant Administrator for 
EPA’s Office of Pesticides, Prevention and Toxic Substances 

Theme 1: Incorporate Prevention into Mainstream Agency Work 

Theme 2: Help Build National Network of Prevention Programs 

Theme 3: Pioneer Environmental Programs Emphasizing Cross-Media Prevention 

Theme 4: Establish New Federal Partnerships 

Theme 5: Generate Environmental Information and Track Progress 

Theme 6: Develop Partnerships in technological Innovation 

Theme 7: Change Federal Environmental Laws to Encourage Pollution Prevention 

Chapter 2 — Looking at Industry.43 

Industry Progress: TRI and Voluntary Programs 

Establishing Corporate Commitment to Pollution Prevention 

Helping Small Businesses to Undertake Pollution Prevention Measures 

Encouraging Industry-wide Initiatives 

Reaching Suppliers and Customers 

Making the Most of Community Involvement 

Selling Environmentally-Preferable Products 

Innovative Ideas 

Guest Commentaries from: 

Edwin L. Mongan, DuPont 

Craig Doolittle, The Dow Chemical Company 

Marc J. Epstein, INSEAD 


i 















Table of Contents 



Page Number 

Chapter 3 — The Role of Other Federal Agencies in Prevention.85 

Federal Agency Pollution Prevention Activities 
Department of Agriculture 
U.S. Agency for International Development 
Department of Commerce 
Department of Defense 
Department of Energy 
General Services Administration 
Department of the Interior 
National Aeronautics and Space Administration 
U.S. Postal Service 
Department of Transportation 
The White House 

Guest Commentaries from: 

Fran McPoland, Federal Environmental Executive 
Sherri Goodman, U.S. Department of Defense 
Christine Ervin, U.S. Department of Energy 

Chapter 4 — Preventing Pollution at the State and Tribal Level.129 

Overview of State Programs 
State Program Activities 
Pollution Prevention on Tribal Lands 
Guest Commentaries from: 

Linda Bray Rimer, North Carolina Department of Environment 
Mary A. Gade, Illinois Environmental Protection Agency 
Andrea Farrell, The National Pollution Prevention Roundtable 

Chapter 5 — Prevention at Educational Institutions: Engaging Future Leaders.163 

K-12 Programs 
University-level Programs 


ii 













Table of Contents 


Page Number 

Guest Commentaries from: 

David Allen, The University of Texas at Austin 
Michael Heiman, Dickinson College 

Jonathan W. Bulkley, National Pollution Prevention Center at the University of Michigan 

Chapter 6 — The Contributions of Community and Non-Profit Organizations.187 

Local/Community-Based Initiatives 
Two Tools for Communities 
Community Issues and Initiatives 
National Non-Profit Organizations 
Guest Commentaries from: 

Paul Orum, Working Group on Community Right-to-Know 
Mary Rosso, Maryland Waste Coalition 

Naomi Friedman, National Association of Counties, and Karen Troccoli, 

National Association of County and City Health Officials 

Chapter 7 — Measuring Pollution Prevention.215 

The Emerging Framework for Measuring Prevention 
Measuring Program Effectiveness in States and Communities 
Measuring Pollution Prevented 
Other Measures for Pollution Prevention 
Guest Commentary from: 

Ken Geiser and Elizabeth Harriman, Toxics Use Reduction Institute 

Chapter 8 — The Future of Pollution Prevention.235 

Guest Commentaries from: 

Joseph T. Ling, 3M 

Warren R. Muir, Hampshire Research Associates, Inc. 

David L. Thomas, Illinois Department of Natural Resources 
Harry Freeman, University of New Orleans 














Joanna D. Underwood, INFORM, Inc. 
Gerald Kotas, U.S. Department of Energy 


Joanna D. Underwood, INFORM, Inc. 

Gerald Kotas, U.S. Department of Energy 

Appendix A - Available Resources.253 

Appendix B - Pollution Prevention Act of 1990.267 

Appendix C - Pollution Prevention: EPA's Statement of Definition.275 

Index.279 


IV 









Foreword 


Foreword 

by 

Carol M. Browner 

Administrator of the U.S. Environmental Protection Agency 
Washington, DC 


Moving from concept to reality — that’s the progress on pollution prevention we are proud to document in Pollution 
Prevention 1997: A National Progress Report. 

Though it has been less than seven years since passage of the Pollution Prevention Act, the idea of reducing or 
eliminating pollution at its source has already gained a firm hold in environmental policy and now manifests itself 
in dozens of EPA programs and initiatives. After two decades of trying to control pollution at the end of a pipe, or 
by treating its effects, we are now operating under the principle that preventing pollution is cleaner, cheaper, and 
smarter than simply playing the shell game — moving contaminants around, from air, to water, to land. 

But the most encouraging progress is being made beyond the offices of EPA in local communities where citizens, 
elected officials, business representatives, and other stakeholders are working together to find common sense solu¬ 
tions to their local pollution problems. 

EPA has sought to encourage their efforts in a variety of ways. For instance, increasing the amount of publicly 
available information on toxic chemicals that are released into the environment has proved to be one of the most 
effective ways to reduce local pollution, because it gives citizens democracy’s most powerful tool — knowledge. 
That’s why we have expanded our Toxics Release Inventory (TRI) to include more chemicals and more industrial 
facilities that must report their toxic emissions. 

Armed with TRI data, countless communities and industry officials have worked together to reduce and prevent 
pollution. Literally thousands of companies, after seeing this comprehensive snapshot of their individual facilities, 
have decided they must prevent pollution — and have taken immediate action to do so. Since 1988, reported 
releases of toxic chemicals have declined by an astounding 46 percent nationwide. 

A growing number of industry leaders are viewing environmental protection not as a regulatory problem but as a 
business opportunity, and thus are doing a better job of monitoring their environmental costs. EPA’s Project XL and 
Common Sense Initiative are designed to encourage businesses to improve their environmental performance, and 
thereby reduce their pollution of the public’s air, land and water. 

States and tribes, as well, are taking measures to make pollution prevention the guiding force of their environmental 
management programs. We at EPA are learning from their groundbreaking efforts and are proud to support them. 

Through partnership efforts, thousands of organizations across America are voluntarily conserving energy and 
water, reducing greenhouse gases, toxic emissions, and solid wastes — and building pollution prevention into the 
heart of their products and their services. 

This report, EPA’s first national report on pollution prevention since 1991, details the progress that is being made on 
all levels — from EPA initiatives and industry programs to the exemplary efforts of states, universities, communities, 
non-profits and conscientious individuals. Across the country, from corporate boardrooms to individual house- 



v 









Foreword 


i ■■ 


holds, a greater awareness of humans impacts on the environment is developing. Herein you will read about the 
nation’s most promising examples of how Americans are preventing pollution and, ultimately, making our commu¬ 
nities more sustainable. 

To be sure, there are still many questions about the future of pollution prevention. They, too, are presented in this 
report. 

But this report offers a great deal of hope that no pollution challenge is too daunting to be overcome by the ingenuity 
of the American people. I hope you enjoy reading it and that you find it a useful reference tool for developing new 
and innovative ways to make our environment safer and healthier for future generations. 


vi 










\\WWV 


. WL 


**-i 


Executive Summary 


Executive Summary 

Pollution prevention first emerged as a watchword for environmental protection in the 
work of Dr. Michael Royston nearly 20 years ago. Royston’s book, “Pollution Preven¬ 
tion Pays,” advanced an idea that has become the basis for an enormous range of 
activity — that preventing pollution, rather than controlling it or cleaning it up, could 
provide both environmental and economic benefits. Environmental protection and 
economic progress could be complementary, not competing, goals. 

Pollution Prevention 1997: A National Progress Report highlights activity in the pol¬ 
lution prevention arena. This report is a sequel to the first such report, issued six years 
ago (Pollution Prevention 1991: Progress in Reducing Industrial Pollutants). Much 
has changed in that short period of time. The level of activity in pollution prevention 
has mushroomed, the concepts underlying pollution prevention have become more 
widely disseminated, and creative solutions and technologies have emerged to deal 
with complex problems. Pollution prevention is on the move, from the boardroom to 
the classroom and from the statehouse to the community center. If there is one 
overarching and encouraging change in the last six years, it would have to be this 
growing enthusiasm for pollution prevention, particularly in education. The spread of 
pollution prevention to elementary schools and high schools, and the interest in “green¬ 
ing” university campuses on the part of students themselves are among the most hope¬ 
ful signs for the future. 

Part of the resurgence of interest in pollution prevention reflects the common sense 
understanding of most people that it is easier to prevent problems than to fix them. 
This common sense understanding is reflected in the environmental management hier¬ 
archy of the Pollution Prevention Act of 1990, in which Congress established as na¬ 
tional policy that: 

■ Pollution should be prevented or reduced at the source whenever feasible; 

■ Pollution that cannot be prevented should be recycled in an environmentally 
safe manner whenever feasible; 

■ Pollution that cannot be prevented or recycled should be treated in an environ¬ 
mentally safe manner whenever feasible; and 

■ Disposal or other release into the environment should be employed only as a 
last resort and should be conducted in an environmentally safe manner. 

Environmental challenges have not gone away in the last six years. Increased popula¬ 
tion and consumption patterns threaten to outpace the gains achieved through environ¬ 
mental statutes. Persistent and bioaccumulative toxic chemicals are found in the envi¬ 
ronment with long term effects that we are only beginning to understand. Waste treat¬ 
ment technologies sometimes transfer pollutants from air to water to land or vice versa. 
A legacy of waste sites presents frustrating challenges for remediation, while dispersed 
and nonpoint sources of pollution represent some of the most intractable problems for 


1 











Executive Summary 


restoring and sustaining environmental quality. Pollution prevention is a primary tool 
for dealing with all of these challenges. 

The intent of this report is to highlight some of the widely differing activities that can 
prevent pollution, and to give readers a sense of the creativity and diversity of partici¬ 
pation in pollution prevention. Given the scope and pace of activity, we have not tried 
to present a comprehensive picture of progress across the country. (In the interests of 
space, we have left international activities out of the report entirely, although we rec¬ 
ognize that prevention approaches are not confined to this country.) The selection of 
material inevitably reflects an EPA perspective. For this reason, we are particularly 
grateful for the perspectives of a distinguished group of guest commenters, who are 
dedicating much of their professional lives to pollution prevention. We are delighted 
to hear their voices and to have this document strengthened by their views. 

While this report points to the great strides that have been made in developing and 
implementing pollution prevention programs, there is still much to be done in pre¬ 
venting pollution itself and measuring progress. We hope that readers will come away 
with a renewed appreciation of the value of prevention, as well as ideas and new ap¬ 
proaches that they can consider adapting to their own situations. 

Each of the chapters in this 
report discusses the pollution 
prevention activities of a par- 
ticular sector of society 
(summarized below). Guest 
commentaries are included in 
each chapter of this report, 
representing organizations 
as diverse as the National 
Association of Counties, the 
Dow Chemical Company, the 
Department of Defense, and 
the North Carolina Depart¬ 
ment of Environment, Health 
and Natural Resources. All 
parts of society have an in¬ 
terest in preventing pollution 
— state and local govern¬ 
ments, educational institu¬ 
tions, community groups, 
non-profit organizations — 
and each group has pollution 
prevention advocates. Al¬ 
though their specific issues may differ, one thing becomes clear as you read what they 
have to say — we share a common goal in preventing pollution. 


Pollution prevention is potentially the most effective method for reducing risks 

to human health and the environment, because it is: 

■ the surest way to avoid the inadvertent transfer of pollutants across media 
that may occur with end-of-the-pipe control approaches, 

■ the surest way to eliminate the risks that are inherent in any release of 
pollutants into the environment, and 

■ the surest way to protect natural resources for future generations, by 
avoiding excessive levels of wastes and residues and by minimizing the 
depletion of resources. 

Pollution prevention is also potentially the most cost-effective method of envi¬ 
ronmental protection, because it: 

■ reduces raw material and energy losses, 

■ reduces the need for “end-of-pipe” treatment and disposal technologies, 
and 

■ reduces long-term potential liabilities associated with releases into the 
environment. 


2 





Executive Summary 



Chapter One — Promoting Prevention at EPA 

Dr. Lynn Goldman, Assistant Administrator for EPA’s Office of Prevention, Pesti¬ 
cides, and Toxic Substances (OPPTS), introduces this chapter, observing that “pres¬ 
sures on the environment are on the rise, in the United States and around the world.” 
Dr. Goldman comments on the connection between the move to reinvent government 
and pollution prevention, noting that both initiatives have the ability to “save re¬ 
sources that can be devoted to further environmental protection.” The remainder of 
this chapter is organized around the seven themes that have provided the focus for 
the Agency’s activities in prevention as identified by Administrator Carol Browner 
in her 1993 Pollution Prevention Policy statement. 

■ Incorporating pollution prevention into the mainstream work of EPA. Much 
of what EPA does involves promulgating, implementing, and enforcing 
environmental regulations. To encourage regulated entities to undertake 
pollution prevention, this mainstream work of EPA must be focused on 
prevention. The Agency has undertaken a concerted effort in the past six years 
to find the best ways to incorporate prevention into regulations and permitting, 
through such efforts as the Source Reduction Review Project and EPA’s 
Common Sense Initiative. EPA has also looked inward, at activities in its own 
facilities, and committed to taking advantage of prevention opportunities. 

■ Building a national network of prevention programs. EPA cannot force or 
encourage pollution prevention on its own; rather it must work with state and 
local governments to develop a national network of prevention programs that 
will assist regulators at all levels of government in promoting pollution 
prevention. EPA is providing funding support, technical assistance, information 
dissemination, and forming federal/state/local government partnerships to focus 
efforts on pollution prevention as the national goal for environmental manage¬ 
ment. 

■ Pioneering cross-media prevention programs, representing new models for 
government/industry interaction. Voluntary programs such as Partners for the 
Environment are EPA/industry interactions aimed at educating industry, 
citizens, state and local governments, and other stakeholders on ways in which 
they can participate in pollution prevention. These partnerships include the 33/ 
50 Program, Climate Wise, Green Lights, WasteWi$e, Design for the Environ¬ 
ment, Project XL, Environmental Accounting,WAVE (Water Alliances for 
Voluntary Efficiency), and Pesticide Environmental Stewardship. 

■ Establishing new federal partnerships. EPA is working with other federal 
agencies to promote pollution prevention across the federal government. The 
partnerships involve establishing policies, implementing programs, managing 
facilities, and acquiring goods and services. 


3 










Executive Summary 


\ V *. 


■ Generating environmental information on pollution prevention. One key to 
pollution prevention is access to information on pollutant sources, types of 
pollution generated, and technologies that can help prevent pollution at the 
source. Programs such as the Toxics Release Inventory (TRI) yield informa¬ 
tion for industry, government, and communities on major types of releases, the 
industrial and government facilities that are releasing them, and the environ¬ 
mental media into which the pollutants are being released. Environmental 
information can be a powerful tool to drive purchasing decisions. EPA’s 
Consumer Labeling Initiative is examining ways to provide consumers with 
better environmental information, including improved product labels. 

■ Developing partnerships for technological innovation in pollution prevention. 
EPA’s partnerships with industry and universities are developing new tech¬ 
nologies for future pollution prevention efforts. These partnerships include 
the Green Chemistry Challenge and an Environmental Leadership Program, 
both of which support facilities that have volunteered to demonstrate innova¬ 
tive approaches to pollution prevention. EPA’s Office of Research and Devel¬ 
opment has invested heavily in developing and analyzing prevention technolo¬ 
gies. 

■ Changing existing federal laws to encourage pollution prevention as the 
preferred method for reducing risks to health and the environment. 

Chapter Two — Looking at Industry 

Although pollution prevention has spread to a wider audience, industry remains at 
the center of pollution prevention activities. Studies have shown that the economic 
benefits are compelling arguments in favor of pollution prevention, but only when 
managers are able to see the cost savings that pollution prevention would bring. Envi¬ 
ronmental accounting is a key factor in demonstrating to businesses the value of pre¬ 
vention. 

One starting place for considering industrial pollution prevention is the TRI main¬ 
tained by EPA. TRI data, which are collected and published annually, show a steady 
decline in the volume of toxic chemicals released to the environment by the manu¬ 
facturing sector. Since 1988, the year TRI reporting was first required, releases of 
hazardous substances have decreased by 44 percent, although the volume of waste 
generated has increased, attributable at least in part to an improving economy and, 
therefore, increased production. One of EPA’s best-known voluntary programs, the 33/ 
50 Program, had a goal of reducing releases of 17 selected chemicals by 33 percent as 
of 1992, and 50 percent by 1995. This program achieved the 1995 goal a year ahead 
of schedule. 


4 


Companies that serve as models for pollution prevention responses have common ele¬ 
ments, beginning with strong management support and commitment. Five large cor¬ 
porations fostering prevention are highlighted: Monsanto and Union Carbide, leading 












Executive Summary 


chemical manufacturers; Public Service Electric and Gas, a utility that used materi¬ 
als management to yield pollution prevention returns; AT&T, which has made inno¬ 
vative use of environmental accounting methods to further its pollution prevention 
goals; and Home Depot, one of the most active retailers promoting a pollution pre¬ 
vention agenda among its clients and staff. 

While larger companies frequently have both the financial and technical resources and 
expertise in-house to implement pollution prevention practices, smaller businesses may 
have a greater need for assistance. These businesses may find it difficult to identify 
opportunities for pollution prevention in their processes and products and may also 
may have fewer resources available to implement the changes, whether in equipment, 
accounting practices, or other areas. Five examples of successful small businesses are 
described, along with information on federal and state programs that are available to 
assist small businesses, including EPA’s Small Business Compliance Assistance Cen¬ 
ters and state Small Business Development Centers. 

Industry pollution prevention initiatives go beyond changes in manufacturing pro¬ 
cesses to include product stewardship programs to reach suppliers and customers with 
a pollution prevention message; working with communities and stakeholders to create 
more sustainable products and expand market share; and selling “green” or environ- 
mentally-preferable products. Innovative ideas and technologies in pollution preven¬ 
tion, ranging from new soldering process for circuit boards to using ultraviolet light to 
coat beer cans (thereby eliminating emissions of volatile organic compounds), con¬ 
clude the chapter. 

Guest author Edwin L. Mongan of DuPont observes that the key to future success lies 
in cooperative efforts involving companies, local communities, regulatory agencies, 
and environmental groups. Craig Doolittle of the Dow Chemical Company points out 
the importance of prevention for global competitiveness, and highlights the value of 
“resource productivity” — using less raw material to make more product with less 
waste. Both authors emphasize the importance of flexible, performance-based envi¬ 
ronmental regulatory programs, and the need to integrate business and environmen¬ 
tal management systems. Marc J. Epstein of INSEAD focuses on three specific tools 
for improving corporate environmental performance: capital investment decision-mak¬ 
ing, cost management, and performance evaluation. 

Chapter Three — The Role of Other Federal Agencies in Prevention 

The federal government is the largest single buyer of goods and services in the United 
States, and the largest property-owner. In its varied roles as purchaser of products, 
facility manager, regulator, and policy maker, the federal government is uniquely situ¬ 
ated to encourage pollution prevention through the example of its own actions. Fed¬ 
eral agencies have become substantially more active in pollution prevention over 
the last six years, under the guidance of legislation and a number of Executive 
Orders. This chapter highlights the varied pollution prevention activities of 11 
federal agencies: 


5 






The U.S. Department of Agriculture’s Sustainable Agriculture Research and 
Education Program provides competitive grants for research, education, and 
extension projects in four regions of the country. The projects help farmers 
reduce pesticide use, manage wastes, and reduce energy consumption. 

U.S. Agency for International Development (U.S. AID) operates an Environ¬ 
mental Pollution Prevention Project which focuses on locally sustainable 
pollution prevention programs for urban and industrial waste in developing 
countries by providing technical assistance for diagnosing problems, training, 
information dissemination, and assistance in program development. 

The Department of Commerce’s National Institute of Standards and Technology 
is assisting industry in technology development through four programs: (1) 
Advanced Technology Program, which provides cost-shared grants for high- 
risk technologies with commercial potential; (2) Manufacturing Extension 
Partnership for small and mid-sized companies; (3) collaborative laboratory 
research with industry; and (4) the Malcolm Baldrige National Quality Award 
outreach program. 

The Department of Defense (DoD) engages in numerous pollution prevention 
activities affecting both military installations and weapon systems. As a major 
user and generator of hazardous substances, DoD has focused on reducing the 
use of these chemicals in its own facilities and by its suppliers. Life-cycle 
assessment is an integral part of these projects. 

The Department of Energy (DOE) also uses, generates, and releases a large 
amount of hazardous substances; its recent successes in addressing this problem 
have earned DOE an “Environmental Champion” award. Each facility is 
responsible for developing pollution prevention goals and determining the best 
method for achieving them. DOE is also working with its contractors to 
encourage and assist them in implementing similar pollution prevention efforts. 

The General Services Administration is one of the largest purchasing units of 
the government and, with EPA, is piloting several projects to evaluate and 
distribute information on environmentally-preferable products. 

The Department of the Interior is approaching pollution prevention and waste 
minimization at the Bureau level. Organizations such as the National Park 
Service and the U.S. Geological Survey are proceeding with plans to reduce the 
amount of toxic materials used, stored, and disposed. 

The National Aeronautical and Space Administration’s (NASA) pollution 
prevention strategy has resulted in a significant reduction in releases of TRI 
reportable substances over the last few years. NASA is using facility-specific 
plans to promote and implement pollution prevention goals. 

The U.S. Postal Service’s Waste Minimization/Pollution Prevention Program 
has resulted in a 76 percent decrease of solid hazardous waste generation since 










Executive Summary 


1992. Changes have occurred in the painting of service vehicles, the use of 
dry cell batteries, recycling of mail trays and pallets, and numerous other 
areas. 

■ The Department of Transportation (DOT) is moving on several fronts to 
integrate pollution prevention into its activities. Reductions in energy use by 
encouraging walking and bicycling, use of recycled materials in asphalt, 
wetlands mitigation, and decreased use of polluting substances are some of 
DOT’s initiatives. 

■ Through the “Greening of the White House” project, President Clinton has 
instituted numerous changes in the operations of the White House to transform 
it into a model for energy efficiency, waste reduction, and environmental 
protection. 

Guest author Fran McPoland, the Federal Environmental Executive, highlights the 
challenges of Executive Order 12873: waste reduction, increased recycling, and pro¬ 
curement of environmentally-preferable products and products with recycled content. 
Sherri Goodman with the Department of Defense points out the accomplishments of 
DoD in environmental protection, and emphasizes its goal of continuous improvement 
in environmental performance through new technologies, new partnerships, smart busi¬ 
ness decisions, and an emphasis on eliminating pollution at its source. Christine Ervin, 
writing on behalf of the Department of Energy, also points out both the strengths and 
the limitations of existing environmental paradigms in the face of growing population 
and resource demands, and maintains that the future belongs to those who best inte¬ 
grate resource efficiency into products and factories. 

Chapter Four — Preventing Pollution at the State and Tribal Level 

States have been in the forefront of innovation in pollution prevention. State activi¬ 
ties have shifted over the last six years, from legislation — in 1992 over half of the 
states had passed some form of legislation promoting pollution prevention — to 
implementation issues, integration of pollution prevention into existing regulatory 
programs, and attempts to measure progress in pollution prevention. 

Some states administer their pollution prevention programs though regulatory agen¬ 
cies with media-specific offices such as air, water, or solid waste. Other states also 
involve nonregulatory agencies, such as university-based technical assistance programs, 
a small business program, and a technology transfer foundation. Implementing these 
programs involves a variety of approaches including technical assistance and outreach, 
mandatory facility planning, and regulatory integration. At least 40 states offer confi¬ 
dential, on-site pollution and waste assessments for small, and sometimes larger, busi¬ 
nesses. Over 30 states operate information clearinghouses on pollution prevention 
and 30 states have some form of pollution prevention facility planning program. States 
also offer hotlines to provide specific information and answer questions, computer 
searches to provide up-to-date information, research on specific pollution prevention 
techniques, workshop and training seminars, publications, and grants and loans, 


7 









Executive Summary 


particularly to small businesses. States are also incorporating pollution prevention 
into regulatory activities such as enforcement settlements, permitting, compliance 
inspections, and waste management. Pilot projects in Massachusetts, Ohio, New 
Jersey, Indiana, and Illinois are described in this chapter. 

As state pollution prevention programs look ahead, they face two primary challenges. 
The first is to evaluate and measure the effectiveness of their technical assistance and 
outreach efforts, in terms of actual pollution prevention results at the company level. 
Second is the ongoing need to integrate pollution prevention into state regulatory 
programs. 

Tribal governments have only recently been able to consider, both economically and 
technically, pollution prevention as an alternative to end-of-pipe controls. Although 
most tribal governments are still in the nascent phase of environmental manage¬ 
ment, since 1992, tribes have received 18 Pollution Prevention Incentives to States 
(PPIS) grants and 14 Environmental Justice through Pollution Prevention (EJP2) 
grants. Several tribes have taken steps to integrate pollution prevention into their 
regulatory and voluntary programs. Critical issue for integration of pollution pre¬ 
vention into tribal activities are the lack of communication among tribes and the 
need for education and outreach on pollution prevention. Tribes, EPA, and state 
agencies are hoping to overcome these barriers by increased tribal participation in 
national conferences and membership in organizations such as the National Pollu¬ 
tion Prevention Roundtable. 

Guest author Linda Bray Rimer of the North Carolina Department of the Environment 
points out the challenges that states face in moving pollution prevention beyond “spe¬ 
cial project” and mainstreaming it into state environmental programs. Mary Gade of 
the Illinois Environmental Protection Agency emphasizes the importance of incen¬ 
tives, collaboration, and partnerships in using prevention to address remaining envi¬ 
ronmental problems, and Andrea Farrell of the National Pollution Prevention 
Roundtable highlights emerging international partnerships for prevention as well. 

Chapter Five — Prevention at Educational Institutions: Engaging Future 
Leaders 

Pollution prevention education is available through graduate school. The last six 
years have seen an explosion of interest in pollution prevention in educational 
institutions. 

In kindergarten through high school, pollution prevention is being added to educa¬ 
tional curricula in order to encourage children to practice pollution prevention at 
school and at home. Educational partnerships and organizations have created mate¬ 
rials that engage children’s imagination and enable them to see the practical results 
of pollution prevention. Examples of these educational programs include the Texas 
“Learning to Be Water Wise and Energy Efficient,” and the active participation cur¬ 
riculum Environmental ACTION. 


8 





Executive Summary 


A number of universities and nonprofit organizations are developing curricular ma¬ 
terials incorporating pollution prevention into courses in business, accounting, engi¬ 
neering, chemistry, finance, and environmental sciences. For example, the Man¬ 
agement Institute for Environment and Business is working with business schools to 
encourage an understanding of how source reduction and waste minimization can 
improve the profitability of a company through environmental accounting, design 
for the environment, life-cycle analysis, and quality management. 

Universities are leading research and development on new pollution prevention con¬ 
cepts, such as life-cycle analysis and industrial ecology. Spurred sometimes by stu¬ 
dents, some universities have become activists in implementing pollution prevention 
on campus. For example, The George Washington University in Washington, DC, 
signed a formal agreement with EPA to incorporate pollution prevention and other 
environmental concepts into all aspects of university life. 

Universities are also a vital source of information for industry and communities. 
There are at least 35 university-based centers for pollution prevention. These centers 
work with industry on technology development and information dissemination, data 
collection, audits, and training and conferences. Many states have established their 
compliance assistance/pollution prevention coordinators at a regulatory agency with 
the technical assistance program located at a university. Universities are forming part¬ 
nerships with federal and state agencies, industry, and local community organizations 
to solve real world environmental problems on a local, regional, and national scale. 

Guest author David Allen of the University of Texas at Austin comments that most 
prevention activities at universities have been grass-roots, but that their long-term 
viability depends on making these activities “the rule, not the exception.” Michael 
Heiman of Dickinson College notes that college prevention programs need not be 
limited to the campus — students have the opportunity to build bridges between the 
campus and the wider community through environmental monitoring. Jonathan W. 
Bulkley of the University of Michigan adds that it is important for colleges and univer¬ 
sities to establish links with pace-setting industrial locations where creative preven¬ 
tion activities are underway. 

Chapter Six — The Contributions of Communities and Non-Profit 
Organizations 

Community involvement has been crucial in achieving many of the pollution preven¬ 
tion successes discussed in this report. Chapter Six discusses two entities that are 
influencing pollution prevention at local, national, and global levels: communities 
and non-profit organizations. 

Community-Based Environmental Protection (CBEP) projects focus on local condi¬ 
tions and problems, recognizing that each community is unique and that solutions for 
one locale are not necessarily applicable to another. CBEP also encourages partner- 


9 



Executive Summary 


ships between public and private entities to address local environmental issues and 
resources. 

While community concerns over industrial pollution are a primary focus for preven¬ 
tion, pollution prevention in the local and regional levels is often interwoven with 
issues of transportation, land use, and building design/indoor air quality. Several local 
initiatives are highlighted in this chapter. 

Prevention has been a primary impetus for several new professional associations, 
including the American Institute for Pollution Prevention and the National Associa¬ 
tion of Physicians for the Environment. Established local government organiza¬ 
tions, including the National Association of Counties and the Center for Neighbor¬ 
hood Technologies, have found a new role in helping to advance prevention among 
their members. Prevention has been the occasion for established environmental groups, 
such as the Environmental Defense Fund and the Natural Resources Defense Council, 
to take on new and expanded roles in collaborative projects. Other groups promote 
prevention by supplying the public with data developed under the TRI. 

Guest author Paul Orum of the Working Group on Community Right-to-Know stresses 
that public access to complete environmental information is key to pollution preven¬ 
tion. Mary Rosso of the Maryland Waste Coalition adds that resources and education 
are the critical factors that make it possible for communities to implement local 
prevention programs. In a joint commentary reflecting the views of the National As¬ 
sociation of Counties and the National Association of County and City Health Offi¬ 
cials, Naomi Friedman and Karen Troccoli discuss the importance of local govern¬ 
ment involvement in prevention programs, acknowledging that one of the challenges 
these kinds of initiatives face on a local level is that prevention is a long-term invest¬ 
ment, in many cases longer than the political terms of elected officials. 

Chapter Seven — Measuring Pollution Prevention 

One sign of the success and maturity of pollution prevention activity is that the focus 
of attention has moved from a concern with program definitions and implementation 
to program outcomes and results. Our questions now are: Will these approaches 
provide benefits in line with the costs? Will there be a net improvement to the 
environment? Chapter Seven provides an overview of both the need for measuring 
progress in pollution prevention and the need for progress in measuring pollution pre¬ 
vention. The chapter discusses two main ways to approach pollution prevention mea¬ 
sures: assessing program effectiveness and determining pollution reductions. 

New regulations and policies have contributed to a growing urgency in the need for 
adequate measures of pollution prevention program effectiveness. As a result of the 
Government Performance and Results Act, the federal government is under increasing 
pressure to assess program effectiveness and eliminate federal programs that are not 
successful. Therefore, a quantitative gauge of the success of pollution prevention 
programs is critical to the long-term survival of these programs. In addition, the Na- 


10 








Executive Summary 


tional Environmental Performance Partnership System, which allows EPA to grant 
more regulatory flexibility to states, imparts an increased responsibility on the part 
of states to demonstrate that they are still meeting environmental goals and objec¬ 
tives. Due to the challenges associated with determining overall statewide pollution 
prevention progress, many states have focused initially on measuring the success of 
specific state pollution prevention program components. 

States, as well as independent research organizations, are determining the extent to 
which specific components of state pollution prevention programs are resulting in 
actual implementation of pollution prevention measures at facilities. Typical mea¬ 
surement methods, which can be used individually or in combination, include: analysis 
of records, reports, and plans; surveys or in-depth interviews (either broadly cover¬ 
ing the universe of relevant facilities, or narrowly focused on recipients of specific 
services); focus groups; and case studies. This chapter describes studies conducted 
by New Jersey, Washington, Massachusetts, North Carolina, and Iowa to evaluate the 
effectiveness of facility planning and/or technical assistance. Studies showed mixed 
results; some companies implemented pollution prevention recommendations result¬ 
ing from on-site technical assistance visits, but costs and quality concerns formed sig¬ 
nificant impediments. 

Three methods of measuring pollution reductions are widely discussed: actual quan¬ 
tity change, adjusted quantity change, and materials accounting. These methods rely 
on data that are readily available to facilities, states, and EPA. The data used to 
calculate actual quantity change or adjusted quantity change can be obtained from 
information reported to EPA’s Toxics Release Inventory or under RCRA. Some states, 
such as New Jersey, also require facilities to submit materials accounting data. Other 
innovative techniques for measuring pollution prevention are also presented in the 
chapter. For example, under a Pollution Prevention Incentives for States grant, the 
Indiana Pollution Prevention and Safe Materials Institute devised a pollution pre¬ 
vention measurement that incorporates hazard rankings for chemicals. The increased 
emphasis on pollution prevention program performance should spur the develop¬ 
ment of better measurement techniques in the years to come. 

Guest authors Ken Geiser and Elizabeth Harriman, writing for the Toxics Use Reduc¬ 
tion Institute, provide a cogent argument for the need to measure prevention. While 
they acknowledge the difficulty of counting something that is prevented (“measuring 
something that exists, such as pollution, is always easier than measuring that which 
has been prevented”), Geiser and Harriman stress that “to promote pollution preven¬ 
tion without metrics and without goals for measurement would promote activity in¬ 
stead of movement and reward effort instead of achievement. Constructing valid and 
appropriate systems for measuring pollution prevention progress is critical to the fur¬ 
ther development of this young field.” 


Chapter Eight — The Future of Pollution Prevention 

What does the future hold for pollution prevention? What are likely to be the great¬ 
est challenges in the years ahead and are we prepared to meet them? Chapter Eight 


11 







Executive Summary 


highlights some of the issues that will affect the future of pollution prevention. We 

have invited a variety of views from long-time prevention practitioners. 

■ Joseph Ling, retired from 3M where he served as Vice President for Environ¬ 
mental Engineering and Pollution Control, outlines his vision for the next step 
beyond pollution prevention and design for the environment — designing for 
sustainability. Ling describes where we have been in environmental protection 
over the past four decades and argues that, while we may not have all the 
answers, it’s time to forge ahead. As he puts it “we need to take that step 
today [toward sustainability], and not worry about stumbling tomorrow.” 

■ Warren Muir, president of Hampshire Research Associates, Inc., acknowledges 
the progress that has been made in recognizing the need for pollution preven¬ 
tion and the increase in pollution prevention activities, but cautions us that 
pollution prevention is far from a mainstream concept and is neither at the 
center of environmental regulatory reform nor a top priority for industrial 
decision makers. Muir finds that pollution prevention “has had no discernible 
impact on aggregate toxic chemical waste generation” while the number of 
source reduction activities reported to TRI has declined each year. 

■ David Thomas, director of the Waste Management and Research Center at the 
Illinois Department of Natural Resources, notes that there is work still to be 
done, but affirms that much has been accomplished. He sees pollution 
prevention as one aspect of a larger environmental revolution that is shaping a 
new, more sustainable future. Challenges that lie ahead include properly 
accounting for the true cost of waste and incorporating pollution prevention 
into the global marketplace. Industry must take a leadership role, colleges 
need to be training youth to integrate environmental thinking into their 
disciplines, and new partnerships must be formed between industry and 
consumers to evaluate environmental problems and design creative solutions. 

■ Harry Freeman, executive director of the Louisiana Environmental Leadership 
Pollution Prevention Program at the University of New Orleans, argues that 
“pollution prevention is a process rather than an end” and suggests that the 
focus of pollution prevention may shift to clean products rather than industrial 
processes and wastestreams, and to federal agencies that have not been as 
involved in the past, such as USDA for non-point source runoff and the Depart¬ 
ment of Transportation for mobile sources of air pollution. 

■ Joanna Underwood, president of INFORM, Inc., argues that the concept of 
pollution prevention has taken center stage in environmental thinking, but the 
reality is not as bright: industry progress in source reduction “has only been 
marginal.” Underwood urges business to find innovative answers to source 
reduction; better data available to the public through materials accounting data; 
and placing the burden of proof on manufacturers to show that new proposed 


12 






Executive Summary 


chemicals are safe for intended uses. “Exposure prevention” should be one of 
our new guiding principles. 

■ Gerald Kotas, co-director of the National Climate Wise Program and senior 
environmental scientist with the Office of Energy Efficiency and Renewable 
Energy of the Department of Energy, traces the history of the federal response 
to pollution and the context for the developing of pollution prevention efforts. 
He calls for partnerships to be formed to develop creative solutions that will 
lead to fundamental changes in our lifestyle that are necessary for a sustain¬ 
able future. Kotas reminds us that at the core of what we are attempting is a 
deeper understanding of the natural connections between economic productiv¬ 
ity, sustainability, and enhancement of environmental quality. 


13 













Executive Summary 



14 


Chapter One 

Promoting Prevention at EPA 



EPA Perspectives on Pollution Prevention by 
Dr. Lynn R. Goldman 

Theme 1: Incorporate Prevention into 
Mainstream Agency Work 

Theme 2: Help Build National Network of 
Prevention Programs 

Theme 3: Pioneer Environmental Programs 
Emphasizing Cross-Media Prevention 

Theme 4: Establish New Federal 
Partnerships 

Theme 5: Generate Environmental 
Information and Track Progress 

Theme 6: Develop Partnerships in 
Technological Innovation 

Theme 7: Change Federal Environmental 
Laws to Encourage Pollution Prevention 


15 









Chapter 1 - EPA 



EPA Perspectives on Pollution Prevention 

by 

Lynn R. Goldman, M.D. 

Assistant Administrator 

Office of Prevention, Pesticides and Toxic Substances 
U.S. Environmental Protection Agency 
Washington, DC 


When I joined EPA’s Office of Prevention, Pesticides and Toxic Substances four years ago, I joined a team of 
pollution prevention advocates - a group of people with great ideas who were working hard to forward pollution 
prevention at the Agency. Shortly thereafter, the “reinvention fever” took over the Agency, as President Clinton and 
Vice President Gore announced their plans to fundamentally reinvent the way the federal government does business. 

This push for greater change came in the context of both substantial progress in environmental protection and 
continuing challenges facing society. For example, while fewer cities were violating ambient air pollution stan¬ 
dards, we learned that asthma was on the rise in children and young people - increasing by 42 percent between 1980 
and 1987. Some experts suspect that environmental exposures are playing a role in this increase. The dichotomy 
between what has been accomplished and what remains to be done arises in virtually every environmental arena. 
Meanwhile, pressures on the environment are on the rise, in the United States and around the world. This situation 
highlights the strengths and the limitations of traditional regulatory approaches that have relied on end-of-the-pipe 
treatment and disposal technologies. It is leading scientists, engineers, researchers, industry, regulators, local offi¬ 
cials, and many others to look for ways to prevent pollution in the first place. 

The emphasis on pollution prevention in reinventing EPA programs respects the fact that society faces many chal¬ 
lenges and that financial resources are limited. It also respects the fact that the environmental problems facing society 
are serious, long-term and fundamental to the health of the planet. Resources saved by preventing pollution, 
reducing red tape, and finding cost savings are resources that can be devoted to further environmental protection. 

While at EPA, I have promoted a mission of expanding the public’s right to know as a way to encourage pollution 
prevention. For example, my office has expanded the Toxics Release Inventory (TRI) significantly in the past three 
years. In 1994, we nearly doubled the number of chemicals on the reporting list. More recently, we proposed to add 
additional facilities to the TRI. And, we are considering a third phase of TRI expansion, focusing on identifying and 
filling additional data needs or “gaps” in the current TRI data that limit the public’s ability to actively participate in 
environmental decision-making that affects their community. The Consumer Labeling Initiative is another important 
part of our efforts to promote the public’s right to know. This project aims to teach us how to effectively present 
helpful environmental, safe use, health and other information on household consumer and pesticide product labels. In 
providing the public information about environmental and health risks through our right-to-know program, EPA aims 
to level the playing field so that all parties concerned about pollution, whether they are affected citizens or workers or 
representatives of government or industry, can discuss the issues openly, speak from a well-informed perspective, and, 
together, develop common-sense solutions. Multistakeholder involvement and public access to information at the 
local level are key features of the new, reinvented system of environmental management. 

I believe strongly in the benefits that come from partnering with industry to achieve mutually advantageous environ¬ 
mental goals. The Office of Prevention, Pesticides and Toxic Substances has played a leadership role in coordinating 
voluntary programs across the Agency, in addition to managing our own Design for the Environment (DfE) partner- 


17 











Chapter 1 - EPA 


ships, 33/50 Program, and the Pesticide Environmental Stewardship Program. Working closely with industry, profes¬ 
sional organizations, and others, DfE has helped businesses incorporate environmental considerations into the design 
and redesign of products, processes, and technical and management systems. The 33/50 program has challenged 
1,300 companies, operating more than 6,000 facilities nationwide, to reduce releases and transfers of 17 high priority 
TRI chemicals. They met that challenge a year ahead of schedule. The Pesticide Environmental Stewardship Pro¬ 
gram, a broad effort by EPA, the U.S. Department of Agriculture, and the Food and Drug Administration, fosters 
reduced pesticide use and risk in both agricultural and nonagricultural settings. By the year 2000, this program aims 
to have more than half of U.S. agricultural acreage adopt environmentally-safer integrated pest management pro¬ 
grams. 

The initiatives I have mentioned here are only a few of the prevention programs championed by my office. And they 
are only a small part of EPA’s overall pollution prevention activities, which have grown significantly since the first 
Pollution Prevention National Report was published in 1991. As you will read in this chapter, all around the Agency, 
there is impressive work being done in prevention. As you learn about some of EPA’s newer cross-program initia¬ 
tives, like the Common Sense Initiative and Project XL, you will notice that our approach to environmental protection 
is fundamentally changing. This reinvention involves not only institutions, but individuals as well. The changes in 
course mean Americans throughout society have the opportunity and the responsibility to participate in environmental 
management decisions and to work creatively to prevent pollution that otherwise would contaminate lakes, rivers and 
groundwater, ambient air, and land. Renewed civic responsibility is taking place at the local, regional, and federal 
levels, and it is very exciting to watch. 

It is equally exciting to me to note the contagious enthusiasm of new prevention advocates across the country. I want 
to take this opportunity to thank in particular the guest authors in this report, who contributed their time and energy 
to provide a diverse set of thoughtful and well-informed perspectives on pollution prevention. While this chapter 
describes how EPA’s prevention program has grown and evolved in these last few years, the examples in the rest of 
this report and the comments of our guest authors demonstrate how enthusiasm for preventive approaches has taken 
hold in industry, other parts of the federal government, state and tribal governments, communities, non-profit 
organizations, and universities. With the commitment of these groups to further institutionalize pollution preven¬ 
tion as the nation’s preferred environmental protection strategy, I am optimistic that together we will continue to see 
pollution prevention success as we enter the 21st century. 


18 


Introduction 


EPA’s pollution prevention program began in earnest in the late 1980s. The goal of 
this program was to add a top step to the U.S. environmental management hierarchy 
— to promote prevention as the preferred environmental protection approach before 
implementing traditional control and clean up approaches. On Earth Day 1993, 
EPA Administrator Carol Browner identified pollution prevention as “the principle 
of first choice” and the new central environmental ethic for all EPA programs. As 
part of its response to Vice President Gore’s National Performance Review, EPA 
accelerated efforts to integrate pollution prevention into all environmental regula¬ 
tions, policy, and guidance. 

This chapter describes some of EPA’s pollution prevention initiatives concentrating on 
how EPA's pollution prevention program, as a whole, has grown since the 1991 
Pollution Prevention National Report. The initiatives can be categorized into seven 
different themes identified by Administrator Browner in her 1993 Pollution Preven¬ 
tion Policy Statement to EPA staff. These themes are listed in the box below. 

Themes Characterizing EPA’s Pollution Prevention Activities: 

1. Incorporating prevention as the principle of first choice into the mainstream 
of the Agency. 

2. Helping to build and facilitate a national network of prevention programs, 
particularly among states and local governments. 

3. Identifying and pioneering new environmental programs that emphasize cross¬ 
media prevention, reinforce the mutual goals of economic and environmental 
well-being, and represent new models for government/industry interaction. 

4. Establishing new federal partnerships to promote prevention within the 
national government. 

5. Generating and sharing environmental information to promote prevention, 
track progress through measurement systems, and better empower consumer 
decisions. 

6. Developing partnerships in technological innovation with the private sector 
to increase industrial competitiveness and enhance environmental stewardship. 

7. Seeking changes, where justified, in federal environmental laws to encourage 
pollution prevention/source reduction. 


Towards the end of the chapter, we provide some examples of how EPA’s regional 
offices have worked with state and local governments and other organizations to 
develop and implement pollution prevention projects in the regions. 





Theme 1: Incorporate prevention as the 
principle of first choice into the mainstream 
work of the Agency. 

In 1992, EPA began a concerted effort to evaluate pollution prevention options for 
numerous new regulations it had under development. Calling its efforts the Source 
Reduction Review Project (SRRP), EPA asked its media offices to identify multime¬ 
dia and pollution prevention approaches that could be used in developing and imple¬ 
menting a number of air, water, and solid waste regulations. 1 In February 1996, EPA 
published an assessment of the SRRP experience. The assessment identifies the 
successes and obstacles encountered in SRRP and makes a number of recommenda¬ 
tions. On the success side, EPA identified pollution prevention approaches in nu¬ 
merous SRRP rules that are partially or wholly adequate for compliance. EPA also 
found ways to increase flexibility in some instances by adding innovative incentives 
in the rules to encourage businesses to choose pollution prevention/multimedia ap¬ 
proaches. These incentives allow companies to find the least-cost ways of meeting 
standards, and will enable many facilities to achieve better environmental results. 

Some specific examples of success in promoting multimedia and pollution preven¬ 
tion approaches through regulations are: 

■ EPA’s Pesticide Formulating, Packaging and Repackaging Effluent Guideline 
(a water rule, promulgated September 30, 1996). This is EPA’s first rule to 
offer industry two limits to choose from: (1) a zero-discharge limit, based on 
benefits solely to water; or (2) a pollution prevention allowable discharge 
limit, based on benefits to all media. Choosing the latter will be cheaper for 
some facilities and will result in fewer total loadings to the environment. 

■ EPA’s historic effort regarding pulp and paper mills provides a model for 
allowing EPA and its stakeholders to evaluate the cross-media effects of air 
and water regulatory options at one time. This has facilitated the exchange of 
data, perspectives, and innovative ideas in a context broader than a single¬ 
medium rulemaking. The promulgation of the first of these rules 
(subcategorized by type of mill) is anticipated in 1997. 

■ EPA’s Carbamates Hazardous Waste Listing (promulgated February 1995) 
identified significant unregulated air releases, uncovered through cross-media 
analysis. The Listing created a concentration-based exemption for waste 
streams related to the air releases, so as to encourage waste minimization of the 
chemical being released to air. 


' EPA, Office of the Administrator and Office of Pollution Prevention and Toxics. Source Reduction 
Review Project (EPA 100/R-92/002, August 1992). The SRRP was assessed in Preventing Pollution 
Through Regulations: The Source Reduction Review Project, an Assessment (EPA 742-R-96-001, 
February 1996). 


20 





These new regulatory approaches are generally not as familiar to regulated entities as 
the more traditional command-and-control approaches.. Accordingly, EPA wants to 
keep working in this area to expand these innovations to more rulemakings, and to 
highlight the opportunities for better environmental performance and flexibility when 
implementing specific regulations. 

Since the publication of its SRRP Assessment, the Agency has been moving forward 
to expand on its successes and to work on overcoming the institutional obstacles to 
pollution prevention and multimedia approaches identified in the Assessment. In 
September 1996, six Office Directors from across EPA regulatory programs met to 
identify next steps. By March 1997, this group had expanded to more than ten when 
they met as the “EPA Office Directors’ Pollution Prevention Forum.” As a result of 
this meeting, they reached agreement on a list of agency regulatory and program¬ 
matic activities that are or will be targeted as priority pollution prevention projects. 
This is an interim list and subject to change, depending on the results of data gather¬ 
ing in numerous rulemakings. 

In a step beyond SRRP, this list addresses both regulatory and programmatic activi¬ 
ties, and is designed to capture a more complete picture of the strategic opportunities 
for pollution prevention in the Agency’s core work. It is hoped that this will lead to 
a more synergistic interaction among various Agency programs in pollution preven¬ 
tion. It is anticipated that, by taking a more expansive view — i.e., possibly combin¬ 
ing regulatory, programmatic, and maybe research and voluntary strategies — the 
Agency may be able to surmount some of the obstacles encountered when promoting 
pollution prevention in a solely regulatory mode, coordinate more effectively inter¬ 
nally, and achieve more for pollution prevention nationally. 

Prevention benefited when the Agency in 1994 reorganized its enforcement pro¬ 
grams and created the Office of Enforcement and Compliance Assurance (OECA). 
This reorganization consolidated the Agency’s enforcement activities under one pro¬ 
gram and provided a basis for a new approach to enforcement that promotes and 
supports pollution prevention. This new approach will allow EPA to maintain an 
imposing enforcement presence as a means of deterrence, but also view traditional 
enforcement as one of a number of tools for achieving the broader goal of compli¬ 
ance. It will also allow EPA to organize national compliance strategies around eco¬ 
nomic sectors, ecosystems, and other entities to best reflect real-world environ¬ 
mental problems and pursue whole-facility, multimedia strategies whenever feasible. 

Already OECA has seen numerous accomplishments in incorporating pollution pre¬ 
vention in its enforcement and compliance programs. Examples of these accom¬ 
plishments include: 

■ The development of Compliance Assistance Centers for four industry sectors 
(automotive service and repair shops, metal finishing, agriculture, and printing). 
The Office of Compliance, within OECA, is developing these multimedia, 
sector-oriented centers to provide “one-stop shopping” for businesses to obtain 
comprehensive, easy-to-understand information on regulatory requirements and 







Chapter 1 - EPA 


The goal of the 
Common Sense 
Initiative is a 
cleaner 

environment at 
less cost to 
taxpayers and 
industry. 


pollution prevention technologies. In addition, since the Office of Compliance 
is organized around commercial sectors rather than by individual environmental 
medium, the Office will be able to take an industry sector perspective to ensure 
that EPA programs and requirements fit together, are understandable, and favor 
pollution prevention. Other Compliance Assistance Centers are under develop¬ 
ment. 

■ A recently initiated program to incorporate pollution prevention into enforce¬ 
ment settlements through the use of Supplemental Environmental Projects 
(SEPs). 

■ The Federal Facilities Enforcement Office (FFEO) within OECA, together with 
EPA's Office of Pollution Prevention and Toxics (OPPT), published the Federal 
Facility Pollution Prevention Planning Guide to help federal facility environ¬ 
mental coordinators strengthen their environmental programs using pollution 
prevention approaches and comply with the pollution prevention planning 
requirements of Executive Order 12856. 

■ FFEO conducted more than 30 multimedia inspections at federal facilities. 

FFEO targeted facilities that had environmental compliance problems that could 
be addressed using pollution prevention and whose processes lent themselves to 
pollution prevention solutions that could be used as prototypes for other federal 
facilities. 2 

The Common Sense Initiative (CSI) is EPA’s most visible effort to create a prevention- 
oriented framework for environmental protection on an industry-by-industry basis. 
CSI operates by sector subcommittees composed of representatives from industry, 
environmental justice, labor, and environmental organizations, and federal, state, 
and local governments. Six industries are serving as pilots in this program: auto¬ 
mobile assembly, computers and electronics, iron and steel, metal plating and fin¬ 
ishing, petroleum refining, and printing. The six sector teams were convened to 
examine the full range of environmental requirements. Each team is looking for 
opportunities to change complicated or inconsistent environmental requirements 
into comprehensive strategies for environmental protection, with an emphasis on 
pollution prevention, instead of pollution controls. Innovation and flexibility are 
being encouraged. The goal is a cleaner environment at less cost to taxpayers and 
industry. 

EPA’s Regional Program Management has been important to the “mainstreaming” 
of prevention. Nearly every region has found important ways to encourage pollution 
prevention and multimedia approaches in its management activities. For example, 
Region I’s New England Environmental Assistance Team is a self-directed team estab¬ 
lished in 1995 to provide comprehensive, multimedia compliance and pollution pre¬ 
vention assistance to selected sectors of the regulated community. Region IV is devel- 


22 


2 EPA, Office of the Administrator. EPA Pollution Prevention Accomplishments: 1994 — Incorporat¬ 
ing Pollution Prevention Into Business Decisions (EPA 100-R-95-001, Spring 1995). 








oping a new comprehensive Regional Pollution Prevention Strategy that engages all 
regional core media programs in creating and conducting pollution prevention activi¬ 
ties in mainstream activities. Region V’s cross-program Pollution Prevention Team 
has created a “Waste Reduction in Our Workplace” initiative to further waste reduc¬ 
tion activities within day-to-day regional activities, such as implementing pollution 
prevention-friendly contracts. In Region VII, pollution prevention support funds pro¬ 
vide interns to the regional media programs for pollution prevention through a com¬ 
petitive selection process. 

In its Pollution Prevention in Permitting Pilot Project, Region X partnered with Intel 
Corporation, the world’s largest semiconductor manufacturer, to develop a model Clean 
Air Act Title V operating permit that incorporates both pollution prevention and per¬ 
mit flexibility. Region VI has begun similar work in this area with the Oklahoma 
Department of Environmental Quality and Imation Enterprises. 


Theme 2: Help build and facilitate a national 
network of prevention programs, 
particularly among states and local 
government. 

EPA recognizes that a key component in making pollution prevention the nation’s 
top priority in environmental protection is support for state and local government 
efforts in the pollution prevention arena. The Agency has focused its efforts on 
building and facilitating a national network of prevention programs that assist state 
and local regulators in promoting pollution prevention initiatives. The cornerstones 
of this support to states and local governments are: (1) EPA funding of state and 
local pollution prevention projects, (2) dissemination of pollution prevention related 
information and technical assistance, and (3) combined participation of federal, state, 
and local environmental leaders in supporting prevention as a main focus of achiev¬ 
ing environmental protection. 

Funding Support 

Through the Pollution Prevention Incentives for States (PPIS) grant program, EPA 
provides $5-8 million each year — a total of over $35 million since 1988 — for state 
and tribal, local, and community pollution prevention programs and initiatives. The 
goal of the PPIS grant program is to assist businesses and industries in identifying 
pollution prevention strategies and solutions for complying with environmental regu¬ 
lations. EPA’s Environmental Justice through Pollution Prevention grants assist com¬ 
munity-based groups in developing collaborative approaches to achieving environ¬ 
mental justice through pollution prevention. In 1995, EPA awarded $4.2 million to 
support this program. In 1996, these grants were funded at $1.9 million, but funds 
rose again to $4.2 million in 1997. 3 


3 EPA, Pollution Prevention News (September/October 1995 and October/November 1996). 
















Chapter 1 - EPA 


While these focused grants provide substantial support to the pollution prevention 
programs of state and localities, they are dwarfed in size by the annual $650 million 
program development grants provided by EPA’s media programs. EPA guidance now 
encourages pollution prevention solutions in various program support and operating 
grants provided to states each year. 

In addition, great potential exists for funding pollution prevention activities with the 
new Performance Partnership Grants (PPGs) and the related National Environmen¬ 
tal Performance Partnership System (NEPPS). PPGs and NEPPS are new Agency 
initiatives bom out of a joint State/EPA Task Force on State Capacity in 1993. This 
task force recommended that EPA and the states adopt a systematic approach to 
increase state capacity and allow for the management of state programs in a way that 
allows each level of government to contribute according to its respective strengths. 
In February 1995, President Clinton announced a “Performance Partnership” pro¬ 
posing that the states be allowed the option of combining funds from individual EPA 
programs in order to achieve improved program performance. Six states signed pilot 
Environmental Performance Agreements with EPA for FY 96. Approximately 30 states 
are working with their respective EPA Regional Offices to negotiate Performance Part¬ 
nership Agreements for FY 97. 4 

Dissemination of Information and Technical Assistance 

In order to assist states and local governments in achieving compliance with envi¬ 
ronmental regulations, and to help promote prevention-oriented programs in gen¬ 
eral, EPA has established several programs that provide current pollution prevention 
information and solutions from around the world. Leading these programs is EPA’s 
homepage (http://www.epa.gov), from which users can access information on all of 
EPA’s pollution prevention programs, and Enviro$en$e (http://es.inel.gov/envirosense/), 
which provides users with information on pollution prevention technologies, proce¬ 
dures, and experience across federal agencies, other governmental organizations, 
manufacturers, suppliers, researchers, and others. At the heart of Enviro$en$e is im¬ 
mediate access, via the Internet, to pollution prevention contacts, including ques¬ 
tion and answer exchanges with environmental professionals world-wide, training 
materials, databases, regulations, and the most recent prevention technologies. 

The Pollution Prevention Act authorizes EPA to work with states to facilitate the use 
of source reduction techniques by businesses in those states. EPA is in the process of 
developing a national network of information centers around the country. The goal 
of the network is threefold: (1) create new state pollution prevention centers for the 
collection, synthesis, and dissemination of information within the state; (2) support 
existing regional information centers; and (3) coordinate work among the new and 
existing centers to reduce duplication of effort and facilities training for the promo¬ 
tion of pollution prevention technologies. The network will also establish informa- 


4 Performance Partnership Fact Sheet on EPA’s homepage “www.epa.gov/states.” 


24 





Chapter 1 - EPA 


tion standards and peer review to ensure that the information is correct and up-to-date. 
In addition, the network will provide pollution prevention technologies information, 
not only to state technical assistance staff, but to other small business assistance pro¬ 
grams such as the Small Business Development Centers and the National Institutes of 
Standards and Technology Manufacturing Extension Partnerships. Functions performed 
by the network will include: making information accessible and easy-to-search, col¬ 
lecting and updating technical information, identifying and maintaining a list of ex¬ 
perts and other sources of information, and providing a standardized format for infor¬ 
mation such as case studies, bibliographies, processes, and vendor information. EPA 
is using a competitive grant format to identify eligible and interested states. By facili¬ 
tating access to regional and other states’ information, the participating states may 
then focus their efforts on meeting the specific needs of industries in their communi¬ 
ties and may also be able to specialize in the type of assistance they provide. 

Federal/State/Local Government Partnerships 

Bringing together federal, state, and local government environmental leaders is an¬ 
other goal of EPA’s pollution prevention program strategy. EPA has implemented 
many pollution prevention initiatives that attempt to encourage and support a part¬ 
nership between the Agency and state and local groups. As an example, EPA pro¬ 
vides support to the National Pollution Prevention Roundtable, an association com¬ 
prised of state, local and other pollution prevention programs, and has supported the 
National Association of Counties (NACO) as it works to introduce elected county 
officials to pollution prevention. The Agency has recently established agreements 
and projects with county and city public health officials, physicians, and others who 
believe pollution prevention is also disease prevention and who can have an immedi¬ 
ate impact on local communities. 

In addition, for the past five years, EPA has provided support to the Forum on State 
and Tribal Toxics Action (FOSTTA). FOSTTA consists of toxics and prevention staff 
at the state and tribal level who share experiences with OPPT staff in an open forum 
several times a year. 

EPA regions, working with states, are also developing multi-regional initiatives. The 
Tri-State Geographic Initiative, led by Region III, is a multimedia environmental study 
involving the states of Kentucky, Ohio, and West Virginia, EPA Regions III, IV, and V, 
the Ohio River Valley Water Sanitation Commission, and local environmental agen¬ 
cies, whose purpose is to identify pollution prevention approaches to reduce pollution 
sources in the tri-state area, addressing both businesses and citizens as sources of pol¬ 
lution and as partners in prevention. The Great Lakes Regional Pollution Prevention 
Roundtable, led primarily by Region V and involving eight states and Ontario, has 
created a powerful regional pollution prevention information and assistance mecha¬ 
nism to help states better address regulatory and other environmental challenges. 


25 













Theme 3: Identify and pioneer new 
environmental programs that emphasize 
cross-media prevention, reinforce the 
mutual goals of economic and 
environmental well-being, and represent 
new models for government/industry 
interaction. 

Over the last several years EPA has created an array of partnership programs de¬ 
signed to promote prevention by challenging businesses and other partners to set and 
meet voluntary pollution prevention goals and commitments. These partnerships 
with businesses, citizen groups, state and local governments, and educational groups 
provide new models for government/industry interaction and are achieving more 
cost-effective solutions to environmental issues than traditional regulatory approaches. 

EPA’s voluntary programs, collectively referred to as Partners for the Environment , 
demonstrate that voluntary goals and commitments achieve real environmental re¬ 
sults in a timely and cost-effective way. 5 The results of the Partners for the Environ¬ 
ment efforts are impressive. Thousands of organizations are working cooperatively 
with EPA to set and reach environmental goals such as conserving water and energy 
and reducing greenhouse gases, toxic emissions, solid wastes, indoor air pollution 
and pesticide risk. More than 6,000 participants from every major sector of the 
economy — from Fortune 500 companies to small shop owners — were involved in 
Partners for the Environment programs in 1995. 

Together, EPA’s Partners for the Environment programs have: 

■ reduced toxic emissions by 750 million pounds; 

■ eliminated 1.8 million tons of solid waste in one year; and 

■ reduced greenhouse gas emissions by preventing 13.4 million metric tons of 
CO, emissions in 1995. 

These programs do not just reduce pollution; they also save energy. The Partners for 
the Environment programs saved 110 trillion BTUs in 1995 — enough to light 11 
million households for a year. The success of these programs is growing dramati¬ 
cally. By the year 2000, with continued participation from even more partners, these 
pollution prevention numbers are expected to triple. 

The voluntary partnerships fostered by EPA’s programs are not just good for the envi¬ 
ronment, they make good business sense and prove that pollution prevention pays. 
Together, these partners saved $435 million in 1995 and expect to save $7 billion 


5 EPA, Office of the Administrator. Partnerships in Preventing Pollution: A Catalogue of the 
Agency’s Partnership Programs (EPA 100-B-96-001, Spring 1996). 



Chapter 1 - EPA 


A Voluntary Partnership Program Success Story 

The 33/50 Program , EPA’s first voluntary pollution prevention reduction ini¬ 
tiative, challenged corporate America to voluntarily reduce toxic emissions of 
17 toxic substances by 33 percent in 1992 — a target which many participating 
firms met or exceeded — and by 50 percent in 1995. EPA received 1,300 indi¬ 
vidual commitment letters from companies that agreed to reduce emissions of 
these toxic substances by 50 percent in less than five years. Data from the 1994 
Toxics Release Inventory (TRI) show that more than 750 million pounds of 
toxic waste have been eliminated by 33/50 participants, allowing the 33/50 
program to claim success in meeting its 1995 goal a year early. This program 
was a recipient of Vice President Gore’s Hammer Award for helping govern¬ 
ment work better and cost less. 

provides technical assistance and puts companies in touch with financial 
services to “jump start” energy efficiency and pollution prevention actions. 

With 13 charter companies, Climate Wise companies already represent almost 4 
percent of U.S. industrial energy use. Climate Wise participants expect to save 
more than $80 million annually by the year 2000. 

■ Green Lights, an EPA program designed to prevent pollution by encouraging 
U.S. institutions to use energy-efficient lighting technologies. EPA forms 
partnerships with individual institutions, including both public and private 
organizations, and asks participants to develop 5 year action plans for reduc¬ 
ing energy consumption through more efficient lighting technologies. In¬ 
spired by the success of Green Lights, EPA introduced Energy Star Buildings, a 
program that takes pollution prevention to new heights. Enjoying the same 
rapid growth as Green Lights, Energy Star Buildings allow participants to 
maximize profitability, increase productivity, and improve occupancy comfort 
through increased energy efficiency. To date, Green Lights and Energy Star 
Buildings participants have distinguished themselves by preventing more than 
4.5 billion pounds of greenhouse gas emissions per year (equivalent to 
removing 480,000 cars from the road); and saving more than $250 million per 
year (reducing operating costs, making organizations stronger and more 
competitive, and reinvesting in the American economy). 

■ WasteWi$e is a voluntary partnership between EPA and U.S. companies aimed 
at reducing inefficient materials use and thus reducing municipal solid waste, 
and conserving energy and natural resources. Through this program, firms 
establish cost-effective goals of their choice to reduce their municipal solid 
waste through prevention, recycling, and by buying or manufacturing recycled 
products. Since the program’s inception, more than 500 companies have 
participated and have saved millions of dollars through prevention and 
recycling of their waste. WasteWi$e partners conserved nearly 344,000 tons of 
materials through waste prevention activities in 1995 - a 40 percent increase 


annually by the year 2000. 
Below are examples of some of 
the Agency’s partnership pro¬ 
grams: 

■ Climate Wise Recognition 
Program is a joint EPA/ 
Department of Energy 
voluntary pledge program 
that encourages private 
industry and others to 
adopt flexible, compre¬ 
hensive approaches to 
reducing greenhouse gas 
emissions. The program 


27 




over 1994 figures. In addition, partners quadrupled the reported amount of 
materials collected for recycling to more than four million tons. WasteWi$e 
partners also reaped significant cost savings. In avoided disposal tipping fees 
alone, the amount of waste reduced represents a potential savings of more than 
$143 million. 6 Again, this voluntary partnership program clearly demon¬ 
strates the cost benefits of incorporating prevention programs into American 
businesses. Both the “bottom line” and our nation’s environment are 
improved. A related program, the Waste Minimization National Plan, targets 
prevention of hazardous waste. The Plan’s goal is to reduce persistent, 
bioaccumulative, and toxic chemicals in hazardous waste by 50 percent by the 
year 2005. 

■ Design for the Environment (DfE), through collaborative ventures, promotes the 
design of safer products and processes in areas such as dry cleaning, screen 
printing and electronics, and harnesses environmental information to advance 
new prevention approaches and technologies among business and industry. 

This program utilizes EPA’s expertise and leadership to facilitate information 
exchange and research on pollution prevention efforts. DfE works with 
businesses, trade associations, and other stakeholder industries to evaluate the 
risks, costs, and performance of alternative chemicals, processes, and technolo¬ 
gies. In addition, DfE helps individual businesses apply specific tools and 
methods to undertake environmental design efforts. 

■ The Agency’s Environmental Accounting Project, a collaborative effort with 
business, academia and others, promotes sound management accounting and 
capital budgeting practices which better address environmental costs. The 
project encourages and motivates business to understand the full spectrum of 
environmental costs, and integrate these costs into decision making. Cur¬ 
rently, the project has over 650 members who are actively participating or 
interested in environmental accounting. Implementing environmental account¬ 
ing will make environmental costs more visible to company managers, thus 
making those costs more manageable and easier to reduce. The project has 
produced numerous tools, such as P2/Finance software, that help companies 
incorporate environmental costs into their capital budgeting decisions. 7 

■ The Pesticide Environmental Stewardship Program (PESP) is a voluntary 
public-private partnership of EPA, the Department of Agriculture, the Food and 
Drug Administration, and groups that use or influence the use of pesticides. 

The program’s goals are to develop specific use/risk reduction strategies that 
include reliance on biological pesticides, integrated pest management, and other 


6 This figure is based on an average 1995 U.S. tipping fee of $32.19 per ton, a value reported by Solid 
Waste Digest in 1995. 

7 EPA, Office of Pollution Prevention and Toxics. Stakeholder’s Action Agenda: A Report of the 
Workshop on Accounting and Capital Budgeting for Environmental Costs (EPA 742-R-94-003, 
December 5-7, 1993). 



Chapter 1 - EPA 


safer approaches to pest control. Voluntary partnerships with PESP will 
significantly contribute to the Clinton Administration’s goal that 75 percent of 
U.S. agricultural acreage adopt integrated pest management practices by the 
year 2000. PESP currently has 48 partners and 10 supporters (organizations 
that influence pesticide use) that represent 45,000 pesticide users. Each partner 
has agreed to develop and implement formal strategies to reduce the use and 
risk of pesticides and to tailor pesticide use to specific sites, crops, and regions 
of the country. 

■ Water Alliances for Voluntary Efficiency (WAVE) is another voluntary 
program similar to Green Lights, that is dedicated to achieving water use 
efficiency. Currently, hotel and motel chains are targeted for participating in 
the program, but other groups such as hospitals and schools will soon be 
involved as well. The primary goals of WAVE are to reduce water and energy 
consumption through the installation of water-efficient equipment, linking 
water-use efficiency to reduced costs, and educating business staff and the 
public on the benefits of reduced water use. The 26 hotel chains now partici¬ 
pating in the program have each signed a Memorandum of Understanding 
with EPA agreeing to develop and implement a plan for reducing water 
consumption at their facilities. Businesses participating in the program are 
expected to cut water use by up to 30 percent and on average, recover the costs 
of investments in water-efficient equipment in just 3 years or less. 

■ In 1995, President Clinton launched Project XL, a program designed to 
encourage development of alternative strategies to achieve greater environ¬ 
mental benefits over current regulatory programs. As part of Project XL, EPA 
is creating partnerships with states to provide a limited number of companies 
with the opportunity to demonstrate their environmental excellence and 
leadership. These companies will be given the opportunity to modify or 
replace current regulatory system requirements at specific facilities with 
company-developed alternative, flexible strategies. Each alternate strategy 
must meet a number of conditions, including: (1) it must produce environmental 
performance superior to that which would be achieved by full compliance with 
current laws and regulations; (2) it must be “transparent” so that citizens can 
examine assumptions and track progress toward meeting promised goals; (3) it 
must not create worker safety or environmental justice problems; (4) it must have 
the support of the community surrounding the facility; and (5) it must be enforce¬ 
able. EPA expects that the program will increase flexibility in adopting innovative 
prevention-oriented solutions to environmental problems, improve compliance and 
increase use of new technologies, and encourage a more cooperative relationship 
among regulators, regulated businesses, and the community. 

I The Merit Partnership for Pollution Prevention (Merit) is a cooperative 
venture of the public and private sectors. Merit, which was initiated by EPA 
Region IX in 1993, is led by a Steering Committee made up of EPA, industry, 
and other government representatives; and a Community Advisory Panel 


"One of my favorite 
DILBERT M cartoons 
says "Change is a 
good thing - you 
first." [Project] XL is 
an experiment in 
leadership in a 
leadership-adverse 
world." 

-- Charles McLean, 
founder of the 
Aspen Institute's 
Series on the 
Environment in the 
21st Century 


29 






Chapter 1 - EPA 


Two Examples of XL Projects: 

1) Intel Corporation Proposes a Multi-media Operating Plan 

The Intel Corporation signed a Final Project XL Agreement in November 1996, beginning the implementation of 
a multi-media environmental master plan at its Ocotillo, Arizona semiconductor facility. The Final Project Agree¬ 
ment was developed by a stakeholder team with intense public participation, including public hearings and a 
national comment period. The plan commits Intel to: 

■ reducing hazardous, solid and non-chemical hazardous waste; 

■ reducing fresh water consumption; 

■ using health-based guidelines for limits on emissions of hazardous air pollutants; and 

■ exceeding current zoning setbacks for its facilities; and 

■ maintaining a cap on air emissions below the minor source level, even if a new facility is built on the site. 

Implementation of these project goals will allow Intel to modify production processes without revising its air 
permits if emissions are below permit levels and make operational changes if the aggregate limit for air pollutants 
is not exceeded and the varying levels do not exceed health-based guidelines. Participation in Project XL will help 
Intel increase its operational flexibility and shorten time-to-market delays. 

2) City of Anaheim Proposes Prevention Activities 

In exchange for committing to certain voluntary actions, the City of Anaheim, California, is seeking relief from 
monitoring requirements for the Acid Rain Program. This Project XL for Communities Proposal (currently in the 
development phase) requires the City to close abandoned wells that currently threaten to contaminate drinking 
water supplies, implement a chlorinated solvents reduction program with local businesses, and implement demon¬ 
stration projects for innovative technologies that reduce use of hazardous chemicals. 

consisting of private citizens and community and environmental organization 
representatives. Merit’s mission is to develop and promote pollution preven¬ 
tion practices and technologies that both protect the environment and contrib¬ 
ute to economic growth. Merit does this primarily by developing and facilitat¬ 
ing the implementation of pilot projects that demonstrate new and innovative 
pollution prevention practices and technologies. Merit projects vary widely in 
scope of effort and in the industries involved, but the one criterion they all 
have in common is a focus on the environmental and economic impacts of the 
technology or practice being tested. 

In Region I, the CLEAN Program capitalizes on OECA’s new small business and 
audit policies to help promote industry/state/EPA partnerships, initially with metal 
finishers in Maine and New Hampshire. Region I’s Environmental Capital Network 
creates a private sector partnership to help new pollution prevention and recycling 
companies improve their business plans in order to attract venture capital. 

The Great Printers Project in Region V has enlisted the Council of Great Lakes Gov¬ 
ernors, the Printing Industries of America, the Environmental Defense Fund, EPA, and 
state environmental and technical assistance agencies to make pollution prevention 
the standard practice in the printing industry. Region II has also targeted the printing 


30 






sector in the New York City area by engaging the New York State Department of 
Environmental Conservation, other state agencies, and printing trade associations in a 
Seminar Series for Printers. 

Under its South Phoenix Pollution Prevention Project for Metal Finishers, Region 
IX has partnered with the State of Arizona, the Lawrence Livermore National Labo¬ 
ratory, the City of Phoenix, and the local chapter of the American Electoplaters and 
Surface Finishers Society to provide pollution prevention technology transfer to metal 
finishers, first reaching those located in an environmental justice community and then 
more broadly around the state. 

The programs described above are just a few of the many successful voluntary part¬ 
nership programs that EPA has initiated in the last 5 years. These programs are in 
effect new models for government/industry interaction in environmental protection. 
As demonstrated, these programs are achieving remarkable results in preventing 
environmental degradation and at the same time are economically beneficial to U.S. 
industries and the American people. 

Theme 4: Establish new federal 
partnerships to promote prevention within 
the national government. 

EPA is establishing partnerships with other federal departments and agencies to pro¬ 
mote pollution prevention both within federal government facilities and within fed¬ 
eral regulatory and guidance programs. Many federal departments and agencies are 
now managing major prevention-oriented federal environmental initiatives. 

Several Executive Orders signed by President Clinton require federal facilities to 
report emissions, to take a leadership role in recycling, and under guidance from 
EPA, to identify and procure “environmentally-preferable products.” 8 EPA’s guidance 
on environmentally-preferable products (EPP), published in the Federal Register on 
September 29, 1995, launched a national debate on “green procurement” principles. 9 
Included in the guidance are seven general guiding principles designed to help execu¬ 
tive agencies begin the process of identifying and purchasing environmentally-prefer¬ 
able products and services. The guidance also recommends implementation activities 
for executive agencies, such as issuing policy directives and applying the principles to 
acquisition. Ultimately, the goal is to establish the federal government, through its 
enormous purchasing power, as a leader in pollution prevention by creating of a strong 


8 "Environmentally-preferable" products and services have a lesser or reduced effect on human health 
and the environment when compared to other products and services that serve the same purpose. 
Executive Order 12783, Sections 201&503 (October 20, 1993). 

9 EPA, Office of Pollution Prevention and Toxics. Environmentally Preferable Products - Proposed 
Guidance (EPA 744-94-002, September 1995) and EPA, Office of Pollution Prevention and Toxics. 
“Guidance on Acquisition of Environmentally Preferable Products and Services; Solicitation of Com¬ 
ments,” Federal Register 60 (189) (September 29, 1995). 


Chapter 1 -EPA 


Spending $200 
billion annually, 
the federal 
government can 
apply its 

purchasing power 
to create a demand 
for products and 
services that have a 
reduced impact on 
the environment. 


31 





Chapter 1 - EPA 


market for “green” products. Two of the environmentally-preferable purchasing pi¬ 
lot projects that have been launched involve acquiring cleaning products and con¬ 
struction products. In both of these projects, EPA is partnering with other federal 
agencies (the General Services Administration and the Department of Defense, re¬ 
spectively) to couple its environmental knowledge with other agencies’ acquisition 
expertise. 

Executive Order 12856, signed by President Clinton in August 1993, requires federal 
facilities owned and operated by federal agencies to report annually to the Toxics 
Release Inventory (TRI). This reporting will ensure that the public has access to infor¬ 
mation on the releases and transfers of toxic substances from these facilities and en¬ 
sures that the federal government is a good neighbor in the communities in which it 
operates. In essence, the Executive Order extends private sector reporting require¬ 
ments to all federal facilities and directs each federal agency to voluntarily decrease 
its toxic releases and off-site transfers by 50 percent using 1994 (the first reporting 
year) as the baseline. Over 190 federal facilities are subject to TRI reporting. (Further 
information on TRI reporting for federal agencies may be found in Chapter 3 of this 
report.) 

Partnership programs between federal agencies are also instrumental in fostering 
pollution prevention programs that serve the clients of the agencies. One example of 
such a partnership is Agriculture in Concert with the Environment (ACE), a joint 
grant program funded equally by EPA and USDA’s Sustainable Agriculture Research 
and Education (SARE) Program. The goals of this competitive grants program are to 
promote agricultural practices and systems that are environmentally sound, economi¬ 
cally viable, and resource conserving. In 1997, ACE will be funded nationally at 
$225,000. 

EPA also provides technical assistance to federal departments or agencies seeking 
assistance in establishing internal pollution prevention programs. Many federal pro¬ 
grams, EPA guidance, case studies, and other pollution prevention initiatives are 
available to federal agencies and are easily accessible via EPA’s Enviro$en$e Web site 
(see discussion earlier in this chapter). 

The National Park Service Project in EPA’s Region VIII has leveraged the pollution 
prevention expertise of the region and the resources of the National Park Service to 
successfully reduce or eliminate solid and hazardous waste streams in more than 35 
national parks, thereby both lowering ecological risks and saving millions of dollars. 
In its environmental workshops, the Long Island Postal Service collaborates with EPA 
Region II to present information on the benefits of pollution prevention gathered from 
several pollution prevention opportunity assessment done under a previous Region II 
initiative. 


32 


Chapter 1 - EPA 


Theme 5: Generate and share 
environmental information to promote 
prevention, track progress through 
measurement systems, and better 
empower consumer decisions. 

A central element of EPA’s pollution prevention strategy is motivating industries to prevent 
pollution by empowering citizens and consumers with environmental information. 

Section 313 of the 1986 Emergency Planning and Community Right-to-Know Act 
(EPCRA) and section 6607 of the Pollution Prevention Act of 1990 require certain 
manufacturers to report to EPA annually the quantities of toxic chemicals they re¬ 
lease to the environment and the amounts of waste managed on-site or transferred 
off-site for management elsewhere. EPA compiles this information and shares it 
with the public annually as the Toxics Release Inventory (TRI). TRI also asks ques¬ 
tions of industry about source reduction, energy recovery, and treatment and disposal 
activities. By making these data public, TRI provides a strong incentive for compa¬ 
nies to reduce wastes. TRI milestones include: 

■ The 1995 TRI data, announced in May 1997, showed that reported industrial 
releases declined by 45.6 percent (1.35 million pounds) from 1988. Of the 
21,951 facilities that reported to TRI for 1995, nearly 29 percent reported 
implementing at least one source reduction activity. 10 

■ In 1994, EPA added 286 additional chemicals and chemical categories to the 
TRI, giving the public a broader picture of progress in preventing toxic waste 
generation and release. 

■ In 1997, EPA expanded by 30 percent the number of industrial facilities 
required to report to TRI, to include the categories of metal mining, coal 
mining, electric utilities, commercial hazardous waste treatment, petroleum bulk 
terminals, chemical wholesalers, and solvent recovery services. In addition, 

700 chemical manufacturing facilities which already report right-to-know 
information to the TRI, will also be required to report on additional types of 
pollution, such as hazardous waste treatment activities. 

■ EPA has reported to the President the benefits that chemical use reporting 
(materials accounting) would have on community right-to-know laws, and has 


‘“These numbers are taken from an initial comparison of 1995 data with the 1988 TRI baseline year as 
reported in EPA, Office of Pollution Prevention and Toxics. 1995 Toxics Release Inventory , Public Data 
Release (EPA 745-R-97-005, April 1997) and 61 Federal Register 51322 (October 1996). The second 
phase of the data release will occur in Fall 1997 and will serve to provide a more in-depth look at the data 
and the trends. This second phase will include the publication of an industry sector-based analysis of trends 
as well as the publication of a comprehensive guide to TRI data use. The sector-based approach will 
compare like facilities to each other and will allow for a sector-based assessment of future prevention and 
technology needs. This sector-based approach will also allow for goal-setting within sectors and across 
facilities. 


"Since pollution 
prevention is 
motivated in part 
by public 

information, one of 
EPA's most 
important tasks is 
to collect and 
disseminate user- 
friendly data that 
measures progress 
in reducing waste 
at its source." 

— EPA Pollution 
Prevention Policy 
Statement 


33 










Chapter 1 - EPA 


How to Obtain TRI Reports and Data Products 

Product Supplier Contact Information 


1995 TRI Public Data 
Release (annual report) 


EPA EPCRA Hotline 

(800) 535-0202 or 
(703) 412-3333 (fax only) 


TRI Information Kit 
(EPA 749-F-94-002) 


NCEPI (513) 489-8180 

(800) 490-9198 


Accessing TRI Data Online 

Data from Online Providers 

Right-to-Know Network (RTKNET)- 
Provides public access to TRI and 
related environmental databases 
to community groups concerned 
about toxics. For more 
information call (202) 797-7200 

National Library of Medicine 
(NLM) - Offers state of the art, 
user friendly searching of 
complete TRI database. For 
more information call (301) 
496-6531. 

EPA Internet Server - Access 
a variety of reports, data 
files and TRI information from 
EPA. For more information 
call TRI-US at (202) 260-1531. 


Internet Address 

ftp://ftp.rtknet.org 

gopher://gopher.rtknet.org 

http://www.rtk.net 


toxnet.nlm.nih.gov 


ftp://ftp.epa.gov 

gopher://gopher.epa.gov 

http://www.epa.gov/opptintr/tri 


Special Notes 

Set computer parameters to 
8,N,1 and log in as “public.” 

No charge for Internet access. 
Direct access by modem at 
(202) 234-8570; phone charge 
may apply. 

$18-20 per hour charge. Password 
required. 


begun an open process to determine how this might best be accomplished, 
including issuing an Advanced Notice of Proposed Rulemaking in October 
1996. 

■ In 1994, under the direction of Executive Order 12856, EPA began to collect 
(for the first time) toxics release data from federal agencies. 

EPA’s new Consumer Labeling Initiative (CLI), is examining ways to provide better 
environmental information on products to consumers, including improved product 
labels. CLI, a pilot project launched in March 1996, invites ideas from consumers, 
industry, and health and safety professionals, on ways to improve the environmental, 
health, and safety information appearing on household product labels. The pilot 
project is specifically targeting home and garden pesticides and household hard sur¬ 
face cleaners. The project’s primary goal is to ensure that consumers have and un- 


34 








derstand the information they need to make responsible product choices based on 
their own needs and values. In addition, EPA hopes to encourage companies manu¬ 
facturing these products to use substances in their products that are less harmful to 
human health and the environment. 11 

Environmental management standards are increasingly used by organizations as a 
means of focusing and managing all of their environmental responsibilities. In Sep¬ 
tember 1996, the International Organization for Standardization’s (ISO) Technical 
Committee (TC) 207 published the first international consensus standard, ISO 14001, 
for environmental management systems. EPA participated actively in the develop¬ 
ment of this and the other ISO 14000 series standards. EPA is testing the utility of ISO 
14001 as a vehicle for enhancing pollution prevention, compliance, and overall envi¬ 
ronmental performance. The EPA Voluntary Standards Network is the means by which 
the Agency participates, with full voting membership, in the U.S. Technical Advisory 
Group (TAG) to TC-207. Through the network, the official EPA representatives to the 
U.S. TAG disseminate information throughout the Agency and coordinate EPA com¬ 
ments on the documents. 12 

Theme 6: Develop partnerships in 
technological innovation with the private 
sector to increase industrial 
competitiveness and enhance 
environmental stewardship. 

EPA is striving, through the use of voluntary partnership programs, to encourage 
and support private sector development of pollution prevention technological inno¬ 
vations. Of particular note is EPA’s Environmental Technology Initiative program for 
new chemicals. The goal of this program is to identify and reduce barriers to the 
development, introduction, and use of safer chemicals and technologies. This project 
offers industry an opportunity to explore new, non-traditional ways to manage risk, 
as opposed to the traditional regulatory approach. 13 

Another EPA project aimed at spurring development of innovative technology is the 
Green Chemistry Program, which aims to reduce or eliminate the use or generation of 
toxic substances in the design, manufacture, and use of chemicals. The program sup¬ 
ports research in environmentally benign chemistry and promotes partnerships with 
industry in developing green chemistry technologies. In March 1995, The Green Chem- 


11 A Phase I Report on the Consumer Labeling Initiative is available on the Internet at http://www.epa.gov/ 
opptintr/labeling/phase 1; or from the Pollution Prevention Information Clearinghouse 
(tel: 202-260-1023, fax: 202-260-0178). For more information, contact Julie Lynch at 202-260-4000. 

12 For more information on the Voluntary Standards Network, contact Mary McKiel at 202-260-3584. 

13 EPA, Office of Pollution Prevention and Toxics. Environmental Technology Initiative for Chemicals 
(EPA 743-K-96-001, May 1996). 








Chapter 1 - EPA 


istry Challenge program was 
announced by President 
Clinton. This program pro¬ 
motes innovative uses of 
green chemistry for pollution 
prevention. EPA is working 
cooperatively with industry 
and the scientific community 
to establish this program. 14 

EPA’s Environmental Lead¬ 
ership Program (ELP) sup¬ 
ports facilities that have vol¬ 
unteered to demonstrate their 
innovative approaches to en¬ 
vironmental management and 
compliance, including pollu¬ 
tion prevention. EPA has se¬ 
lected 12 facilities to partici¬ 
pate in the pilot program and 
will work with these facilities 
to study and evaluate their in¬ 
novative approaches. The in¬ 
formation collected through 
this program will be used as 
a tool to improve environ¬ 
mental management and 
compliance throughout the regulated community. The purpose of ELP is two-fold: (1) 
to recognize facilities that develop and implement innovative environmental manage¬ 
ment systems and “beyond compliance” programs, and (2) to work with these facilities 
and understand their systems and programs and to share that information with the 
regulated community to improve environmental management and increase compliance. 
In exchange for volunteering to demonstrate their innovative approaches, EPA will 
offer facilities several incentives, including public recognition by EPA as an environ¬ 
mental leader, a limited grace period to correct any violations discovered during the 
pilot program, and a guarantee of no routine inspections by EPA or the state. 15 Fifteen 
facilities participated in the pilot program, including ten private companies and two 
federal facilities. 

Region IX's planned Pollution Prevention Through Technology Transfer pilot project 
will help test OPPT’s new pollution prevention risk assessment framework, developed 
in an earlier OPPT/Kodak project, and will help regional industries promote facility- 


Green Chemistry Challenge 

The Green Chemistry grant and awards program provides financial support and na¬ 
tional recognition for research, development, and use of industrially and economi¬ 
cally-viable chemical alternatives. Nominations for the Green Chemistry Challenge 
awards are made in three areas: (1) use of alternative synthetic pathways, (2) use of 
alternative reaction conditions, and (3) the design of chemicals that are less toxic 
than current alternatives or that are inherently safer with regard to accident poten¬ 
tial. The 1996 winners of the award are: 

■ The Monsanto Company for creating a new “zero-waste” process for manu¬ 
facturing a key intermediate in their popular herbicide Roundup®; 

■ Dow Chemical Company for finding a way to replace the CFCs and other 
volatile organic compounds in the manufacture of foam products by using 
carbon dioxide; and 

■ The Donlar Corporation for inventing two processes to manufacture 
polyaspartates, a polymer alternative to toxic chemicals in fertilizers that is 
not only biodegradable but will actually increase nutrient uptake by plants. 

■ Rohm and Haas Corporation, for designing its product “Sea-Nine” as a safer 
marine anti-foulant for boat and ship hulls. 

■ Professor Mark T. Holtzapple at Texas A&M University, for research in using 
agricultural wastes in a wide variety of products, including animal feed, fuels, 
and high value chemicals. 


14 EPA, Office of the Administrator. Partnerships in Preventing Pollution - A Catalogue of the Agency’s 
Partnership Programs (EPA 100-B-96-001). 

15 EPA, Office of Compliance. Environmental Leadership Program Fact Sheet (April 1995). 

36 




based pollution prevention activities. 


Pollution Prevention Research in EPA’s Office of Research and 
Development (ORD) 

ORD has maintained a significant research program in pollution prevention for several 
years. Prior to 1994, the following were the main emphases of this research: assisting 
small business sectors (such as printing, metal finishing, dry cleaning) in achieving 
pollution reduction; developing tools (such as life cycle assessment) to analyze and 
measure pollution prevention potentials; partnering with industry (such as pulp and 
paper) in evaluating cleaner technology demonstration under the Effluents Guidelines 
Program; evaluating innovative waste reduction technologies (under the Waste Re¬ 
duction Innovative Technology Evaluation Program [WRITE]) developed in universi¬ 
ties, research institutes, and industry; working in partnership with other government 
departments in developing specific technologies or assessing opportunities for pollu¬ 
tion prevention; and creating databases for disseminating information about pollution 
prevention. There was also a program to examine the socioeconomic aspects of pre¬ 
venting pollution. Most of these programs are still being supported; however, there 
has been a strategic shift in research direction, the results of which will be felt in a few 
years. The central theme to the strategic shift was the use of risk as a driver and 
motivator for doing prevention research. Thus, only the high priority problems need 
to be addressed first — problems in which either pollution prevention approaches will 
provide large environmental benefits or for which efficient tools and methods will 
provide knowledge and information to reduce uncertainty of prevention technologies 
or to lead to newer prevention approaches. An expanded grants program at ORD 
supports high-risk innovative pollution prevention approaches, and addresses socio¬ 
economic issues of pollution prevention. 

Current ORD research in prevention can be described in four categories: 

■ Development of analytical tools and methods needed to assess or measure 
pollution, and quantify improvements; 

■ Development of generic technologies that have simultaneous appeals to many 
industry sectors and to agricultural practices; 

■ Development of, in collaboration with industry, sector-specific technologies 
requiring systems approaches; and 

■ Demonstration and verification of cleaner technologies on large scales. 
Analytical Tools and Methods for Pollution Prevention 

Providing tools and methods that aid scientists, engineers, and technicians in choos¬ 
ing cleaner chemistry, materials, algorithms, design techniques, databases, and engi¬ 
neering methods when they design for the environment, is effective insurance that 




Chapter 1 - EPA 


industry will of its own accord meet or exceed regulatory requirements. Examples of 
these tools and methods are: 

■ Life Cycle Assessment (LCA). The present thrust of ORD efforts is directed to 
making LCA affordable through a streamlined LCA methodology. 

■ Simulation/Design Tools. The National Risk Management Research Laboratory 
(NRMRL) has developed a computer-based algorithm, WAR or Waste Reduc¬ 
tion Algorithm, that follows the concept of pollution balance, a scheme based 
on either pollution mass or potential environmental impact. WAR will shortly 
be available commercially as a new capability of Chemcad, a product of 
Chemstation, Inc., of Houston, Texas. 

■ Guidance and Design Tools. These computer-based tools (SAGE - solvent 
alternative guide; CAGE - coatings alternative guide; AAGE - adhesives 
alternative guide; and PARIS II) offer ways of selecting environmentally- 
preferable substitutes. 

■ Assessment Tools. ORD has developed guidance documents for systematically 
assessing pollution prevention opportunities in production, service, and 
maintenance facilities. 

■ Impact Assessment Tools. NRMRL is developing a generic program (TRACI) 
for the reduction and assessment of chemical impacts, which assists in 
providing aggregate impacts through user-provided weighing factors for 
various disparate impacts, such as ozone depleters and greenhouse gases. 

■ Control Algorithms. ORD has developed control algorithms based on fuzzy 
logic which allow better control of processes to minimize emissions. 

Generic Process Technologies (Multi-sector) 

Generic technologies have multi-sector impacts. These are products of traditional 
unit operations (physical changes) or unit processes (chemical changes)-based re¬ 
search except that environmental concerns are incorporated in the research process. 
Unlike the analytical tools, which are mathematics- and computer code-intensive, re¬ 
search in generic technologies is largely experiment-based. The following are three 
broad areas of particular interest: 

■ Green Chemistry and Green Processing. The ORD grants program, Technolo¬ 
gies for Sustainable Development, provides significant support for a range of 
generic technologies from cleaner chemical or biochemical pathways to 
chemical synthesis or material formulation. For instance, synthesis in 
supercritical carbon dioxide offers certain processing advantages. Biochemi¬ 
cal synthesis of feedstocks likewise is looked upon as a safer alternative to 
synthesis based on petroleum-derived feedstocks. NRMRL is evaluating 
innovative oxidation pathways that are environmentally benign. A large 
number of valuable feedstocks are oxychemicals, commercially made in 
Sharsher environments, thereby creating unwanted and toxic byproducts. 


38 



■ New Materials. ORD's grants program supports developing new materials, 
such as benign substitutes and materials, with enhanced environmental 
performance. 

■ Separation technologies. The ORD grants program also supports research on 
separation technologies. Separation technologies are particularly suitable for 
making in-process recycle-reuse possible. As an example, consider absolute 
alcohol, which is made from the azeotropic composition of alcohol-water 
mixture. Benzene is added to the binary azeotrope and the ternary mixture is 
further distilled to produce absolute alcohol. With a pervaporation membrane 
this operation can now be done without the need of adding a carcinogenic 
compound like benzene. Numerous opportunities of in-process efficient 
separations are encountered in industrial applications. ORD is currently 
exploring several promising generic separation methods — membrane, 
adsorption, and a hybrid of the two. 


Sector-specific Technology Development 

ORD is following the needs of technology developments in all the CSI industries. 
ORD works with the Office of Water in the Effluent Guidelines Program for evaluating 
cleaner technologies in identified industry sectors, and has recently started working 
with the textile industry under the AMTEX program in developing pollution preven¬ 
tion technologies, such as recovering color from textile effluents and dealing with the 
solid waste problem. 


Technology Demonstration and Verification 




There are certain applications of clean technologies that need to be demonstrated or 
verified for performance before the technologies will be adopted for industrial appli¬ 
cations. A small-scale application of this may be a technology for recycling chro¬ 
mium or nickel from electroplating baths. A large scale application may be paper 
pulp bleaching without using either chlorine or chlorine dioxide. To encourage wider 
acceptance of environmental technologies in general, ORD has formulated an Envi¬ 
ronmental Technology Verification (ETV) program, a part of which is dedicated to 
pollution prevention technologies. 


Theme 7: Seek changes, where justified, in 
federal environmental laws that will 
encourage pollution prevention/source 
reduction. 

The federal Pollution Prevention Act is not the only legislation with significance for 
pollution prevention. U.S. environmental laws have historically been oriented to¬ 
wards single-medium, end-of-pipe waste management solutions. Congressional re¬ 
sponse to waste management problems has been issue- and media-specific, resulting 




in statutes such as the Clean Air Act (CAA), Safe Drinking Water Act, Resource 
Conservation and Recovery Act (RCRA), and the Superfund law. 

These statutes were not designed to encourage preventive approaches, although in 
practice they often have that effect. For example. Superfund liability has been a long 
standing incentive for pollution prevention, since the surest way to avoid future li¬ 
ability is to avoid generating wastes in the first place. The single media approach 
also has its limitations. Because most environmental statutes focus on a single envi¬ 
ronmental medium or problem, they may allow for shifting of wastes between media, 
and not highlight the advantages of eliminating waste at the source. 

The National Academy of Public Administration (NAPA) has recommended that Con¬ 
gress pass legislation encouraging businesses to go beyond mere compliance with EPA 
regulations while at the same time giving industry more flexibility in its approach to 
meeting or exceeding the regulations. NAPA recommends that EPA and Congress, 
working together, design environmental programs and regulations that permit busi¬ 
nesses to seek their own solutions to their individual or common problems. The re¬ 
sults of this type of legislation and regulation are lower costs with the added benefit of 
innovative technology as industries test new methods for achieving pollution preven¬ 
tion targets. 

EPA’s Statutory Integration Project came out of a recommendation by NAPA in its 
Report to Congress. They articulated what many recognize: namely, that EPA is 
fragmented by media, in part due to the statutory framework under which the Agency 
operates. The Senate Appropriations Committee asked the Agency to take a look at 
statutory integration specifically, and also asked the Agency to better integrate its plan¬ 
ning, budgeting, and accountability practices — a process now well under way. 

EPA Administrator Carol Browner charged the Statutory Integration Task Force with 
taking a broad view of the topic. The group is not focused solely on investigating a 
complete statutory “fix,” but is instead looking at a range of possibilities from a 
single integrated statute to replace the existing environmental laws, to incremental 
change working toward better coordination across statutes, to an integrating statute 
which would overlay existing statutes. The task force has conducted approximately 
80 interviews within EPA, with industry, with the regulated community, with envi¬ 
ronmentalists, academics, and Congress. The task force is also working with Re¬ 
sources for the Future on a comparison of international environmental laws, and are 
performing a comparative legal analysis of existing statutes. 

Some key points that are beginning to emerge include a set of objectives which would 
provide EPA with more discretion to set priorities, clearly articulate a mission and 
goals, and provide more flexibility to waive or adjust regulatory requirements. This 
project presents many opportunities to the Agency, including gaining flexibility in 
choosing the best authority to address a risk; functioning in a more integrated way on 
such things as regulation writing; operating with more consistency across authori¬ 
ties; and managing resources more flexibly. 



This brief survey of Agency activity demonstrates how prevention perspectives and 
approaches have taken hold. It is not an assertion that the work of institutionalizing 
pollution prevention across EPA has yet succeeded. In fact, one of the most daunting 
tasks that has faced EPA is integrating pollution prevention into the Agency’s own 
culture and mission. Substantial progress has been made on this task in the last six 
years. Throughout the Agency, EPA offices are rethinking their programs, making 
pollution prevention a priority rather than an afterthought. A wealth of new partner¬ 
ships have been created with the private sector to develop and experiment with pol¬ 
lution prevention approaches. In many ways, pollution prevention has brought with 
it a new sense of cooperation and exploration in tackling some of the most intractable 
environmental problems. At this point, the Agency needs better tools to disseminate 
these prevention innovations across the environmental community and to measure 
the cumulative environmental impacts of these innovations. 

In looking ahead, it is worth considering the five criteria for environmental manage¬ 
ment policies established by the President’s Council on Sustainable Development in 
its 1995 report. 16 These criteria are aimed at enhancing the efficiency of existing 
regulatory systems and are a basis for future environmental approaches as well: 

■ Provide Greater Regulatory Flexibility with Accountability. The regulatory 
system must givecompanies and communities greater operating flexibility, 
enabling them to reduce their costs significantly in exchange for achieving 
superior environmental performance. While allowing flexibility, the system 
must also require accountability to ensure that public health and the environ¬ 
ment are protected. 

■ Extend Product Responsibility. A voluntary system of extended product 
responsibility can be adopted in which designers, producers, suppliers, users, 
and disposers accept responsibility for environmental effects through all 
phases of a product’s life. 

■ Make Greater Use of Market Forces. Sustainable development objectives must 
harness market forces through policy tools, such as emissions trading, deposit/ 
refund systems, and tax and subsidy reform. This approach can substantially 
influence the behavior of firms, governments, and individuals. 

■ Use Intergovernment Partnerships. Federal, state, and tribal governments 
need to work together in partnership with local communities to develop place- 
based strategies that integrate economic development, environmental quality, 
and social policymaking with broad public involvement. 

■ Encourage Environmental Technologies. The economic and environmental 
management systems need to create an atmosphere that encourages innovation 
and the development and use of technologies that will create jobs while 
reducing risks to human health and harm to the environment. 


^President’s Council on Sustainable Development. Council Report. Washington, DC (1995). The 
Report is available on the Internet at http://www.whitehouse.gov/PCSD. 














Chapter 1 - EPA 













Chapter Two 


Looking at Industry 


■ Industry Progress: TRI and Voluntary 
Programs 


■ Establishing Corporate Commitment to 
Pollution Prevention 

■ Helping Small Businesses to Undertake 
Pollution Prevention Measures 

■ Encouraging Industry-wide Initiatives 

■ Reaching Suppliers and Customers 

■ Making the Most of Community 
Involvement 

■ Selling Environmentally-Preferable 
Products 

■ Innovative Ideas 

■ Guest Comments: 

Edwin L. Mongan, DuPont 

Craig Doolittle, The Dow Chemical Company 
Marc J. Epstein, INSEAD 


43 




























































Chapter 2 - Industry 


Introduction 

Reducing and preventing industrial pollution has been the primary focus of this nation’s 
pollution prevention agenda over the past decade. Quantifying the progress that in¬ 
dustry has made in adopting a pollution prevention approach remains elusive. (See 
Chapter 7 of this report for a more detailed discussion of Measuring Pollution Preven¬ 
tion.) However, anecdotal evidence suggests that reliance on pollution prevention as 
a primary environmental management tool is increasing and spreading beyond the 
initial industry leaders. Still, much work remains to be done. This chapter begins with 
some thoughts on motivating industry to prevent pollution. Why should industry prac¬ 
tice pollution prevention? How can those that influence industry decision makers (gov¬ 
ernments, customers, suppliers, workers, non-profit groups, communities, etc.) effectively 
encourage pollution prevention? 

In 1995, EPA completed an ambitious project to examine how a pollution prevention 
ethic could be promoted throughout industry. According to the findings of the Indus¬ 
trial Pollution Prevention Project (IP3), the four most important general motivators 
for pollution prevention in industry are economics, technical and financial assistance, 
open communication, and flexibility (especially regulatory flexibility). 1 The IP3 found 
that the key “trigger” for pollution prevention is a stringent regulation or enforcement 
action. Research conducted by the non-profit group INFORM on the chemical and 
paint and adhesives industries similarly found that the desire to avoid being subject to 
regulations provided the most critical impetus for pollution prevention, not only moti¬ 
vating source reduction initiatives but also ensuring their success in the marketplace. 2 
Similarly, in a 1994 study of global competitiveness in six industries, environmental 
pressures from regulations and from consumers and professional advocacy campaigns 
created opportunities for companies to gain competitive advantage in domestic and in¬ 
ternational markets. 3 Such innovations resulted in cost reductions, yield improvements, 
market share increases, and/or export expansion. 

The economic benefits of pollution prevention have proven to be the most compelling 
argument for business to undertake prevention projects. In a 1992 follow-up study of 29 
firms originally examined in 1985, INFORM found a heightened level of awareness and 
activity related to pollution prevention. Nearly half of the companies were saving be¬ 
tween $45,000 and $1 million annually on their source reduction activities, with 15 
percent saving $1 million or more. Payback periods were short; in nearly two-thirds of 
the source reduction activities, companies recouped their investments in 6 months or 
less. 4 


1 EPA, Industrial Pollution Prevention: Incentives and Disincentives (EPA-820-R-94-004, August 
1994). Also see: EPA, Industrial Pollution Prevention Project (IP3): Summary Report (EPA-820-R- 
95-007, July 1995). 

2 INFORM, Stirring Up Innovation: Environmental Improvements in Paints and Adhesives (New 
York, NY, 1994). 

, 3 Management Institute for Environment and Business, Competitive Implications of Environmental 
Regulations: A Study of Six Industries (Washington, DC, 1994). 

| 4 Dorfman, Mark H., Warren R. Muir, and Catherine G. Miller, Environmental Dividends: Cutting 
More Chemical Wastes (INFORM, 1992). 


The four most 
compelling 
motivators for 
pollution prevention 
in industry are: 

■ economics 

■ technical and 
financial assistance 

■ open 

communications 

■ flexibility (especially 
regulatory flexibility) 


45 





Chapter 2 - Industry 


Cost savings from prevention come not only from avoiding environmental costs like 
hazardous waste disposal fees, but also from avoiding costs that are often more chal¬ 
lenging to count, like those resulting from injuries to workers and ensuing losses in 
productivity. In that sense, prevention is not only an environmental activity, but also 
a tool to promote worker safety. 

So, if preventing pollution is so good for the bottom line, why don’t companies al¬ 
ways do what’s good for them? One answer might be that managers don’t always 
realize the benefits that prevention would bring to their own firms. “Environmental 
accounting” — a new type of managerial accounting that helps firms identify envi¬ 
ronmental costs and benefits — is just now beginning to take hold and to demon¬ 
strate to companies how much of their costs are attributable to environmental 
activities. 5 

The basic idea of environmental accounting is that an organization’s environmental 
costs, like all its costs, need to be identified, quantified, and allocated to the process or 
product that incurs them in order for such costs to be managed and reduced. If 
companies pay closer attention to the size and causes of their environmental costs, 
they will have an economic incentive to prevent them from occurring in the first 
place. Fewer than 10 percent of U.S. manufacturing firms routinely allocate envi¬ 
ronmental costs to the responsible product or process in their internal accounting 
systems, according to a 1995 survey of 150 firms. 6 Another study that closely exam¬ 
ined the accounting systems of nine industrial firms found that “the environmental 
costs teased out of hiding turned out to be colossal.” 7 

Similarly, pollution prevention can offer companies exciting opportunities to increase 
market share, but only if managers have the foresight to realize these opportunities 
and if their firms are well-positioned in the industry. Michael Porter of Harvard Uni¬ 
versity and Claas van der Linde of St. Gallen University in Switzerland have devel¬ 
oped a dynamic model of competitive business behavior showing that market share 
can be captured by companies that continually innovate. 8 But, as Porter and Linde 
advise, “companies must begin to recognize the environment as a creative opportunity 
rather than as a costly threat.” Large companies in industries with a high rate of change 
(e.g., computer and chip manufacturers) tend to have the most resources for innova- 


5 See EPA chapter of this report for a description of EPA’s Environmental Accounting project. A 
bibliography of sources for companies that have realized pollution prevention opportunities by using 
environmental accounting tools, in addition to complete case studies from AT&T and Ontario Hydro, 
are available through EPA’s Pollution Prevention Information Clearinghouse at 202-260-1023. 

6 Tellus Institute, Environmental Cost Accounting for Capital Budgeting: A Benchmark Survey of 
Management Accountants (1995). 

7 World Resources Institute, Green Ledgers: Case Studies in Corporate Environmental Accounting 
(1995). The study examined the books of Du Pont, Amoco, Ciba-Geigy, S.C. Johnson, Dow Chemical, 
and three small firms in the Pacific Northwest. In the case of one Du Pont plant studied, environmen¬ 
tal costs made up 19 percent of the total cost of manufacturing an agricultural pesticide. At an Amoco 
facility, aggregate environmental costs were estimated at nearly 22 percent of operating costs. 


46 


8 Michael E. Porter and Claas van der Linde, “Green and Competitive: Ending the Stalemate,” 
Harvard Business Review (September/October 1995). 



Chapter 2 - Industry 



tion. On the other hand, some industries cannot meet the challenge, particularly if 
they are made up of small companies that are required to make large fixed invest¬ 
ments. 9 

Companies are often stymied by the up-front costs that pollution prevention appears to 
require. According to the findings of the IP3, “while pollution prevention measures 
can hold the promise of future cost savings, if capital investment is needed for such 
changes, companies... can find themselves in a Catch-22 situation.” 10 Nevertheless, 
relatively few companies have reached the point where only capital-intensive mea¬ 
sures are available. A 1992 INFORM report examined pollution prevention activities 
at a variety of facilities in the organic chemical industry and found that no capital 
investment was required for one quarter of the 48 source reduction activities; invest¬ 
ments of under $100,000 were required for about half the activities. * 11 In addition, over 
the past 5 years, loan and grant programs have become more readily available to assist 
companies interested in investing in pollution prevention. 

This chapter begins with an overview of industrial pollution prevention progress 
demonstrated through two prominent EPA initiatives — the required reporting of 
toxic releases to EPA’s Toxics Release Inventory (TRI) and EPA’s voluntary partner¬ 
ship programs, known collectively as “Partners for the Environment.” The remainder 
of this chapter reviews different approaches to industrial pollution prevention and some 
of the lessons that have been learned over the past six years in promoting a pollution 
prevention ethic. 

The examples in this chapter are drawn from a wide variety of industries. While 
most industrial pollution prevention reports tend to focus on the chemical and manu¬ 
facturing sectors, for this report, we have drawn from a wider range of industries — 
from retail stores to utilities to agriculture — to highlight opportunities to prevent 
pollution across the board. However, it would be impossible to cite all of the compa¬ 
nies that have achieved impressive pollution prevention successes. The specific ex¬ 
amples described here are illustrative of diverse approaches to prevention. 

Industry Progress: TRI and Voluntary 
Programs 

The clearest measure of industrial pollution in the manufacturing sector can be found 
in companies’ annual reports of environmental releases of toxic chemicals to TRI. 
Correspondingly, one of the clearest indicators of corporate responsiveness to the need 

I for reducing chemical releases and preventing pollution has been a company’s partici¬ 
pation in EPA’s voluntary programs. 

9 Management Institute for Environment and Business, Competitive Implications, cited in EPA, 
Pollution Prevention News (March-April 1995) pp. 4-5. 

10 EPA, Office of Water. Industrial Pollution Prevention: Incentives and Disincentives (EPA 820-R- 
94004, August 1994). p.2. 

11 Dorfman, Mark H., Warren R. Muir, and Catherine G. Miller, Environmental Dividends: Cutting 
More Chemical Wastes (INFORM, 1992). 


47 









Chapter 2 - Industry 


TRI Data 

The TRI data 12 collected and published annually demonstrate a steady decline in the 
volume of toxic chemicals released to the environment by the manufacturing sector. 
However, over the last several years, the total amount of wastes generated has been 
rising. TRI data for 1995 show a decline of 4.9 percent in releases of core chemicals 
reported in both 1994 and 1995. Overall, from the baseline year of 1988 until 1995, 
total releases (for chemicals reported in each of the years) decreased by 1.35 billion 
pounds, a 45.6 percent decline. However, total production-related waste generated 
in 1995 from all TRI chemicals was over 35 billion pounds, a 6.8 percent increase 
since 1991. 

Companies report pollution prevention activities to the TRI, as required under the 
Pollution Prevention Act of 1990. Of the 21,951 facilities reporting to TRI for 1995, 
nearly 29 percent claimed to have undertaken at least one source reduction activity. 
This is down from 32 percent in 1994. Most commonly reported were “good operat¬ 
ing practices”followed by process modifications, and spill and leak prevention. In 
general, facilities project little change in how they expect to handle their waste in the 
next several years. 

Individual industries have had very different experiences with TRI chemical releases 
and reductions. As Table 2-1 shows, several industries reported reductions of half or 
more of total releases since 1988, led by the electrical equipment industry (79.7 per¬ 
cent) and leather goods manufacturers (77.8 percent). In 1995, the chemical manufac¬ 
turing industry continued to rank in first place with the largest amount of chemicals 
released (36 percent of total releases), followed by the primary metals industry (15 
percent), paper (11 percent), and plastics (5 percent). 

The top 10 chemicals released into the environment (shown in Table 2-2) account for 
over half the total amount of releases of the expanded list of 643 TRI chemicals. The 
10 companies that reported the highest total releases of toxic chemicals in 1994 are 
shown in Table 2-3. Although these firms represented fewer than 2 percent of all TRI 
reporting facilities, they accounted for 26 percent of total TRI releases in 1994. 

It is important to note that the volume of TRI chemicals released does not necessarily 
equate to the amount of risk posed to the public. TRI reports reflect release of chemi¬ 
cals, not exposure of the public to those chemicals. Because health risk is dependent 
not only on toxicity but also on exposure, release estimates alone are not sufficient to 
calculate adverse effects on human health and the environment. 


12 For more information on the 1995 TRI data, see: EPA, 1995 Toxics Release Inventory: Public Data 
Release (EPA 745-R-97-005, April 1997). 


48 










Chapter 2 - Industry 


Table 2-1. TRI Releases by Industry 

Industry 

Percentage 
Change in Releases, 
1988-1995 

Total Releases, 
1995 

(millions of pounds) 

Electrical Equipment 

-79.7% 

30.5 

Leather 

-77.8% 

3.1 

Measurement/Photography 

-74.2% 

16.9 

Tobacco 

-72.2% 

1.7 

Machinery 

-67.6% 

23.2 

Textiles 

-56.1% 

17.8 

Chemicals 

-49.8% 

787.7 

Printing 

-48.3% 

31.6 

Stone/Clay/Glass 

-47.1% 

36.0 

Transportation 

-44.4% 

110.0 

Petroleum 

-40.6% 

59.9 

Fabricated Metals 

-40.1% 

82.6 

Primary Metals 

-38.2% 

331.2 

Furniture 

-33.7% 

41.0 

Plastics 

-31.1% 

112.2 

Food 

-27.5% 

86.0 

Paper 

-12.6% 

233.2 

Lumber 

- 5.0% 

31.3 

Apparel 

+33.6% 

1.3 


Source: EPA, 1995 Toxics Release Inventory: Public Data Release (EPA 745-R-97-005, 
April 1997), Tables 4-10, 5-5. 


Table 2-2. Top 10 Chemicals Released/Disposed, 1995 


Chemical 

Number of Pounds 
(millions) 

Methanol 

245.0 

Ammonia 

195.1 

Toluene 

145.9 

Nitrate compounds 

137.7 

Xylene (mixed isomers) 

95.7 

Zinc compounds 

87.6 

Hydrochloric acid 

85.3 

Carbon disulfide 

84.2 

n-Hexane 

77.4 

Methyl ethyl ketone 

70.0 

Total for top 10 chemicals 

1,224.1 

Total for all TRI chemicals 

2,208.7 


Source: EPA, 1995 Toxics Release Inventory: Public Data Release, Overview (EPA 745-R- 
97-005, April 1997), Table 6. 


49 






Chapter 2 - Industry 


TRI Data 

The TRI data 12 collected and published annually demonstrate a steady decline in the 
volume of toxic chemicals released to the environment by the manufacturing sector. 
However, over the last several years, the total amount of wastes generated has been 
rising. TRI data for 1995 show a decline of 4.9 percent in releases of core chemicals 
reported in both 1994 and 1995. Overall, from the baseline year of 1988 until 1995, 
total releases (for chemicals reported in each of the years) decreased by 1.35 billion 
pounds, a 45.6 percent decline. However, total production-related waste generated 
in 1995 from all TRI chemicals was over 35 billion pounds, a 6.8 percent increase 
since 1991. 

Companies report pollution prevention activities to the TRI, as required under the 
Pollution Prevention Act of 1990. Of the 21,951 facilities reporting to TRI for 1995, 
nearly 29 percent claimed to have undertaken at least one source reduction activity. 
This is down from 32 percent in 1994. Most commonly reported were “good operat¬ 
ing practices”followed by process modifications, and spill and leak prevention. In 
general, facilities project little change in how they expect to handle their waste in the 
next several years. 

Individual industries have had very different experiences with TRI chemical releases 
and reductions. As Table 2-1 shows, several industries reported reductions of half or 
more of total releases since 1988, led by the electrical equipment industry (79.7 per¬ 
cent) and leather goods manufacturers (77.8 percent). In 1995, the chemical manufac¬ 
turing industry continued to rank in first place with the largest amount of chemicals 
released (36 percent of total releases), followed by the primary metals industry (15 
percent), paper (11 percent), and plastics (5 percent). 

The top 10 chemicals released into the environment (shown in Table 2-2) account for 
over half the total amount of releases of the expanded list of 643 TRI chemicals. The 
10 companies that reported the highest total releases of toxic chemicals in 1994 are 
shown in Table 2-3. Although these firms represented fewer than 2 percent of all TRI 
reporting facilities, they accounted for 26 percent of total TRI releases in 1994. 

It is important to note that the volume of TRI chemicals released does not necessarily 
equate to the amount of risk posed to the public. TRI reports reflect release of chemi¬ 
cals, not exposure of the public to those chemicals. Because health risk is dependent 
not only on toxicity but also on exposure, release estimates alone are not sufficient to 
calculate adverse effects on human health and the environment. 


12 For more information on the 1995 TRI data, see: EPA, 1995 Toxics Release Inventory: Public Data 
Release (EPA 745-R-97-005, April 1997). 


48 






Chapter 2 - Industry 


Table 2-1. TRI Releases by Industry 

Industry 

Percentage 
Change in Releases, 
1988-1995 

Total Releases, 
1995 

(millions of pounds) 

Electrical Equipment 

-79.7% 

30.5 

Leather 

-77.8% 

3.1 

Measurement/Photography 

-74.2% 

16.9 

Tobacco 

-72.2% 

1.7 

Machinery 

-67.6% 

23.2 

Textiles 

-56.1% 

17.8 

Chemicals 

-49.8% 

787.7 

Printing 

-48.3% 

31.6 

Stone/Clay/Glass 

-47.1% 

36.0 

Transportation 

-44.4% 

110.0 

Petroleum 

-40.6% 

59.9 

Fabricated Metals 

-40.1% 

82.6 

Primary Metals 

-38.2% 

331.2 

Furniture 

-33.7% 

41.0 

Plastics 

-31.1% 

112.2 

Food 

-27.5% 

86.0 

Paper 

-12.6% 

233.2 

Lumber 

- 5.0% 

31.3 

Apparel 

+33.6% 

1.3 


Source: EPA, 1995 Toxics Release Inventory: Public Data Release (EPA 745-R-97-005, 
April 1997), Tables 4-10, 5-5. 


Table 2-2. Top 10 Chemicals Released/Disposed, 1995 


Chemical 

Number of Pounds 
(millions) 

Methanol 

245.0 

Ammonia 

195.1 

Toluene 

145.9 

Nitrate compounds 

137.7 

Xylene (mixed isomers) 

95.7 

Zinc compounds 

87.6 

Hydrochloric acid 

85.3 

Carbon disulfide 

84.2 

n-Hexane 

77.4 

Methyl ethyl ketone 

70.0 

Total for top 10 chemicals 

1,224.1 

Total for all TRI chemicals 

2,208.7 


Source: EPA, 1995 Toxics Release Inventory: Public Data Release, Overview (EPA 745-R- 
97-005, April 1997), Table 6. 


49 











Chapter 2 - Industry 


"When EPA 
proposed the 33/50 
Program, we 
recognized that its 
general objective 
was no different 
than ours." 


Table 2-3. Top 10 Companies Based on Total Releases Reported to TRI, 
1994 


Company 

Total Facilities 

Releases 

(millions of pounds) 

Du Pont 

70 

203.6 

ASARCO Inc. 

11 

69.4 

Renco Group Inc. 

12 

66.1 

IMC Global Inc. 

13 

47.7 

International Paper Co. 

71 

43.1 

General Motors Corp. 

112 

36.8 

Courtaulds United States Inc. 

9 

34.5 

Monsanto Co. 

27 

27.4 

Arcadian Partners LP 

8 

26.4 

Georgia-Pacific Corp. 

90 

26.2 

Total for top 10 companies 

423 

581.2 

Total for all TRI facilities 

22,744 

2,260.2 


Source: EPA, 1994 Toxics Release Inventory: Public Data Release, Executive Summary (EPA 
745-S-96-001, June 1996), Table E-l. 


- Aristech Chemical 


Partners for the Environment 

EPA has been developing and aggressively promoting voluntary partnerships as an 
alternative to the traditional command-and-control regulatory approach. Programs 
such as Green Lights, the 33/50 Program, WasteWis$e, Climate Wise, and WAVE 

challenge businesses to pre- 


Why Do Industries Join EPA's Voluntary Programs? 

Industry participation in the 33/50 Program has proven remarkably successful and 
is responsible for an accelerated reduction in the 17 chemicals targeted by the 
program. The 1,300 corporate participants in the 33/50 Program own more than a 
quarter of the total number of TRI facilities, and were able to meet the program’s 
1995 goal of 50 percent reduction a year ahead of schedule. Participants in 33/50 
applauded the program’s flexibility and voluntary, “no-strings-attached” terms. An 
interesting insight offered by Aristech Chemical in reflecting on the success of the 
33/50 Program is that the program greatly improved government/industry rela¬ 
tions: “When EPA proposed the 33/50 Program, we recognized that its general 
objective was no different than ours. Therein lies a major reason for the success of 
the program. The progress realized under 33/50 typifies the success that can be 
achieved when government and industry work in pursuit of mutually agreed upon 
objectives.” 13 




vent pollution and improve 
their company’s bottom line. 
Collectively, these partner¬ 
ship programs are known as 
Partners for the Environ¬ 
ment, and they are produc¬ 
ing impressive results. As 
noted in Chapter 1, in 1995, 
over 6,000 participants 
saved $435 million while 
helping to cut toxic pollu¬ 
tion, reduce solid waste, 
and lower greenhouse gas 
emissions. 


13 “The Smart Choice,” Environmental Champions, a supplement to Chemical Engineering and 
Environmental Engineering World, undated, p. 16. 


50 










Figure 2-1. Participation in Partners for the Environment Continues to 
Increase 


Chapter 2 - Industry 


20000 - 

16000- 

12000 - 

8000- 

4000- 

0 - 



* Projected 


Interest in these programs continues to grow - participation increased by 25 percent 
in the last year alone (Figure 2-1). EPA now projects that by the year 2000, the 
number of partners will nearly triple and the total savings to firms will approach $7 
billion a year. 

Establishing Corporate Commitment to 
Pollution Prevention 

A 1993 study by the Business Roundtable, an association of business executives, con¬ 
firms what many believe — successful corporate pollution prevention programs begin 
with tangible forms of corporate commitment. 14 The goal of the Roundtable’s 
“benchmarking” study was to determine the common, as well as the unique, ele¬ 
ments of six “Best-In-Class” manufacturing facilities: Proctor & Gamble’s Mehoopany, 
PA facility; Intel in Aloha, OR; Du Pont in La Porte, TX; Monsanto in Pensacola, FL; 
3M in Columbia, MO; and Martin Marietta in Waterton, CO. 

Key findings of the study included: 

■ All facilities had strong management support and a focal point for the facility 
level pollution prevention program. 

■ Successful facilities understood their corporate and plant cultures and imple¬ 
mented their pollution prevention programs in a way that worked within those 
cultures. 


14 The Business Roundtable. Facility Level Pollution Prevention Benchmarking Study (November 
1993). 


51 























Chapter 2 - Industry 


Corporations can be 
threatened by their 
substantial emissions 
to the environment or 


The majority of the facilities stated that the corporate role should be to 
establish corporate goals with facility input, develop and deploy pollution 
prevention technology transfer across the company, and forecast future 
compliance issues. 

Facilities were successful when they were not told how to approach pollution 
prevention by corporate environmental groups or other outside forces. The 
freedom to choose the best pollution prevention method for their organization 
was key to success. 


challenged by them. 
They can be stymied 
by long-standing 
environmental 
disputes or motivated 
to solve them. They 
can be defensive about 
existing operations or 
open to ideas for 
change. The decisions 
they make at these 
crossroads define the 
role they will play in 
environmental 
decision making, as 
well as their corporate 
image. 

— Linda Greer, 

Natural Resources 
Defense Council 
(Quoted in Monsanto’s 
Environmental Annual 
Review, 1995.) 


■ Facilities had the ability to report progress against selected goals or initiatives 
on a monthly or quarterly basis. 

■ To be able to sustain a pollution prevention program, the projects were, on the 
whole, cost effective. Unlike compliance projects, pollution prevention 
projects generally had to compete against capital improvement projects. 

■ Each facility measured the success of its program differently, using a combina¬ 
tion of reduced cost, reduced volume, improved public image, results against 
goals, ability to expand a facility, and other measures. 

■ Some facilities normalized waste volume to production; others did not. Each 
facility used a different method for tracking wastes/emissions. All facilities 
used PC-based systems to track waste streams and customized spreadsheet 
packages to meet their own needs. 

■ Each of the facilities had matured from focusing on pollution prevention 
within current manufacturing processes to integrating pollution prevention in 
the pre-manufacturing decision phases. The benchmark facilities were 
working with raw material suppliers, equipment suppliers, and customers to 
prevent pollution at each step. 

The following summaries of pollution prevention programs illustrate how pollution 
prevention has been incorporated into five large corporations. Monsanto instituted the 
Monsanto Pledge, a highly effective statement of principles and commitment which 
has been backed up by competitions, awards, and other motivational elements. Union 
Carbide has been recognized by EPA’s Office of Pollution Prevention and Toxics for 
innovative chemical design. Public Service Electric and Gas (PSE&G) provides an 
interesting example of how materials management decisions can yield pollution pre¬ 
vention returns, and how a company can engage in the successful marketing of by¬ 
product materials. AT&T has made innovative use of environmental accounting meth¬ 
ods to further its pollution prevention goals. And Home Depot is one of the most 
active retailers promoting a pollution prevention agenda among its clients and staff. 


52 





Chapter 2 - Industry 


Monsanto 

Monsanto is a major manu¬ 
facturer of high performance 
chemicals, high-value agri¬ 
cultural products, industrial 
process control equipment, 
food ingredients, and phar¬ 
maceuticals. In March 
1996, Vice President A1 
Gore and members of the 
President’s Council on Sus¬ 
tainable Development pre¬ 
sented Monsanto with the 
Presidential Award for Sus¬ 
tainable Development for its 
work in pioneering sustain¬ 
able technologies. 


The Monsanto Pledge 

The Monsanto Pledge — seven principles that describe the company’s vision for a 

sustainable environment — was unveiled during a speech in 1990 by then Chairman 

and Chief Executive Officer Richard J. Mahoney at a meeting of the National Wild¬ 
life Federation. 

■ Reduce all toxic and hazardous releases and emissions, working toward an 
ultimate goal of zero effect. 

■ Ensure no Monsanto operation poses any undue risk to our employees and 
our communities. 

■ Work to achieve sustainable agriculture through new technology and prac¬ 
tices. 

■ Ensure groundwater safety. 

■ Keep plants open to our communities and involve the community in plant 
operations. 

■ Manage all corporate real estate, including plant sites, to benefit nature. 


During the 1990-1994 time ® Search worldwide for technology to reduce and eliminate waste from our 
period, Monsanto achieved a operations, with the top priority being not making it in the first place. 

55 percent reduction in TRI 
chemicals. In making this 

reduction, Monsanto prioritized source reduction with the specific goal of not 
transferring pollutants cross-media. Monsanto faced this challenge when con¬ 
sidering two wastewater projects. Although the projects would have reduced 
TRI chemical output, they would have increased levels of other wastes not in¬ 
cluded in the TRI list. The company felt that following this strategy would 
simply be pollutant transfer, not pollution prevention, and opted not to under¬ 
take the projects. In the future, the company plans to continue focusing much of 
its efforts towards sustainability and, consequently, further reduce TRI emis¬ 
sions. 15 


To achieve the 55 percent reduction, Monsanto completed more than 250 projects 
that involved developing innovative new manufacturing technology and modify¬ 
ing processes; phasing out inefficient operations; applying new pollution con¬ 
trols; and using waste materials for recycling, reuse, and energy recovery. Spe¬ 
cific pollution prevention accomplishments include the following: 

■ Teams from several Monsanto facilities developed a new process to make 
4-aminosiphenylamine, an ingredient that makes rubber products more 
durable. The new patented process called PPD-2 reduced raw material 
needs by 58 percent and cut organic and inorganic waste by a combined total 
of 95 percent. 16 


15 Conversation with Dennis Redington of Monsanto on September 6, 1996. For further information, 
he can be contacted at 314/694-6503. 


16 


Monsanto. Monsanto's 90 Percent Air Emissions Reduction Program. 


53 









Chapter 2 - Industry 


■ Monsanto switched from a well-established process using extremely hazardous 
substances including formaldehyde, ammonia and cyanide-based chemicals to a 
new, highly innovative process that eliminates these hazardous substances from 
the manufacture of the pesticide Roundup®, replacing them with more benign 
chemicals. This new process is saving the company $4 million a year that used 
to be spent managing more than 5 million pounds of waste. In July of 1996, 
EPA presented a “Green Chemistry Challenge” Award to Monsanto for this 
achievement. 17 

■ The Monsanto Butvar resin facility in Antwerp, Belgium, redesigned its facility 
to save energy, reduce water usage, and cut back effluent. Butvar is a material 
used in the plastic innerlayer of safety glass in automobiles and in certain paints 
and adhesives. The first part of the project captures heat from the hot water 
system overflow and uses it in the manufacturing process. The cooled overflow 
is used to replenish water lost in the system. The result is a reduction of 
effluent to the Antwerp treatment plant of 16 tons per hour. The second part of 
the project involves saving and re-using wash water several times in different 
parts of the manufacturing process. Monsanto estimates that it saves more than 
$400,000 a year in water and energy use as a result of this new process. 18 

Union Carbide 

OPPT’s New Chemicals Pollution Prevention Recognition Project recognized the Union 
Carbide Corporation for developing an innovative surfactant, or detergent, for use in 
industrial settings. 19 The material can be split prior to environmental release, which 
results in two non-polluting fragments or byproducts. Union Carbide developed the 
new surfactant to meet its industrial laundry and metalworking customers’ needs for a 
product that would satisfy the effluent composition limits of publicly owned treatment 
works (POTWs). This new technology reduces biological oxygen demand (BOD) and 
fats, oils, and grease (FOG) in effluents. Other prevention benefits of this new mate¬ 
rial include: generating less solid waste; generating solid waste that is higher in or¬ 
ganic content and, therefore, can be put to a more beneficial use as fuel; and reducing 
the use and discharge of phosphates. 

Public Service Electric and Gas 

PSE&G is the fourth largest combination electric and gas utility in the nation, serv¬ 
ing 2.2 million electric and gas customers over a 2,600 square-mile service territory 
in New Jersey. PSE&G’s vast size and diversified power generation and service 


17 EPA Press Advisory (July 12, 1996) and personal conversation with Larry O’Neill, Monsanto, 
(December 4, 1996). 

18 Monsanto. “Butvar™Solvent and Butvar™RB Utility Usage Reduction,” Monsanto Backgrounder, 
(1995). 

19 For more information about OPPT’s New Chemicals Pollution Prevention Recognition Project, 
contact Ken Moss (202-260-3395) or Roy Seidenstein (202-260-2252) of EPA/OPPT. 



Chapter 2 - Industry 


activities require substantial materials support, the costs of which increased sharply 
during the 1980s. 

In 1990, in the face of escalating material costs, PSE&G formed a senior-level Mate¬ 
rials Management Study Team to develop innovative strategies to reform its material 
management process to control costs, improve service to internal customers, and real¬ 
ize environmental benefits. This effort led to a wholesale paradigm shift in PSE&G’s 
approach to materials management. For example, instead of managing materials 
under the old-fashioned notion of “just-in-case” (i.e., purchasing and maintaining 
surplus supplies to meet any unanticipated future needs), PSE&G’s new approach is 
founded on a “just-in-time” concept (i.e., purchasing and stocking only that amount 
of material necessary to satisfy planned needs in the immediate future). Similarly, 
instead of viewing used or surplus materials as wastes (and liabilities), PSE&G’s new 
strategy emphasizes that such materials are potential resources (and assets). 

At the same time as the company changed its materials management system, it also 
focused immediate increased attention on recycling and source reduction, setting 
goals of reducing by 30 percent the total amount of hazardous waste PSE&G gener¬ 
ates, and recycling 75 percent of all non-hazardous solid wastes. PSE&G was honored 
as a 1996 WasteWi$e Program Champion for its Comprehensive Waste Reduction 
Program. The company surpassed these 1995 goals a year early — it reduced hazard¬ 
ous waste generation by 43 percent and recycled 94.5 percent of all company-gener¬ 
ated non-hazardous solid waste. This percentage for non-hazardous solid waste in¬ 
cludes coal combustion by-products (principally coal ash) generated by the company, 
all of which it successfully marketed (e.g., cement/concrete admixture, flowable fill, 
structural fill, pavement base, asphalt filler, cement kiln feedstock, anti-skid road grit, 
blasting and surface prep products, and as a landfill cover). PSE&G estimates that it 
saves $19-24 million annually as a result of its new materials management system. 
The company attributes most of this savings to a decrease in the operations and main¬ 
tenance cost of maintaining an extensive inventory and increased procurement lever¬ 
age. 20 

AT&T 

Changing the accounting systems of an industry giant such as AT&T 21 is by no means 
an overnight operation. AT&T began to develop such a change in 1993, when it named 
Brad Allenby as Research Vice President for Technology and Environment, and set up 
a Design for the Environment Coordinating Team, one of whose projects was “green 
accounting.” 


We do not see a need 
to choose between 
good environmental 
practice and good 
business operations. 
Rather, we believe in a 
Shared Vision -- that a 
cleaner, healthier 
environment can, 
indeed, should go 
hand in hand with a 
strong economy and 
the highest standard 
of living and quality of 
life in the world. 


- James Ferland, 
Chairman and Chief 
Executive Officer and 
Lawrence Codey, 
President and Chief 
Operating Officer, 
Public Service Electric 
and Gas (“Our 
Commitment to the 
Earth,” January 1993). 


20 Public Service Electric and Gas Company. Initial XL Proposal of Public Service Electric and Gas 
(December 1995). 

21 EPA “Environmental Accounting Case Studies: “Green Accounting at AT&T.” (EPA 742-R-95-003, 
September 1995). 


55 




Chapter 2 - Industry 


Recognizing that green accounting must involve a number of traditionally separate 
perspectives and functions, AT&T management saw a multi-functional team approach 
as the only viable planning option. Over time, the initial nine-member team ex¬ 
panded to include members representing supply line management, design engineer¬ 
ing, process engineering, environmental engineering, cost accounting, and financial 
policies nationwide and overseas. Team meetings took place every month, gradually 
shifting to one meeting every 6 to 8 weeks. 

Among the early challenges faced by the Green Accounting Team were the issues of 
terminology and language, and the need for a baseline. For example, should green 
accounting include both “private costs” (costs that impact a firm’s bottom line) and 
“societal costs” or externalities (the impacts of pollution on society and the environ¬ 
ment)? The team recommended that AT&T define green accounting, for now, in terms 
of private costs and also proceeded to develop a glossary for the many terms specific 
to environmental accounting. 22 In addition, the team felt that given the variability 
within the company in treating overhead costs, AT&T must set a baseline of current 
practices to help target opportunities. 

The green accounting team also embraced AT&T’s use of the principles of activity- 
based costing (ABC) and activity-based management (ABM). ABC is a method for 
assigning relevant costs to products by identifying the resources consumed by activi¬ 
ties performed for these products (e.g., a telephone, computer, etc.). But, since “track¬ 
ing costs alone does not drive improvements,” AT&T also uses ABM to determine the 
“causes” or “drivers” of activities and their costs — placing the focus on such areas as 
product or process design, supplier qualification, etc. 

In order to develop baseline information, the team developed a self-assessment tool 
that AT&T plants could use as an aid in establishing baselines and goals for improve¬ 
ment. The self-assessment tool includes a status survey to raise awareness of how 
decisions are currently made, what information is used, and whether environmental 
activities are reflected in product and process costing; and a green activities/resources 
matrix, which requires the user to identify what information is important. 

Three sites reviewed the self-assessment tool, providing feedback on its usefulness 
and suggestions for further refinements. As of June 1995, the Green Accounting Team 
had identified an ambitious agenda of future projects, including bringing environmen¬ 
tal cost considerations into play for any future plant start-ups and divestitures, and 
tying in with the Green Index, an AT&T software tool being developed to assist de¬ 
signers in scoring the environmental attributes of a product. 

Home Depot 

Home Depot, 23 one of the nation’s largest home improvement retailers, helped pio¬ 
neer the first U.S. private sector program to partner retailers, manufacturers, and 

22 Few companies outside of the utility sector in North America have moved to incorporate externali¬ 
ties into their accounting systems. 

23 Source for this section is Home Depot’s Web page on the Internet at http://www.homedepot.com. 

56 



Chapter 2 - Industry 


third-party environmental certification to promote continuous environmental improve¬ 
ment in consumer products. 

Home Depot’s efforts go back a number of years. In 1991, Home Depot published its 
Environmental Principles, subsequently adopted by the National Retail Hardware As¬ 
sociation and Home Center Institute, representing over 46,000 U.S. retail hardware 
stores and home centers. The company started using recycled content materials for 
store and office supplies, advertising, signage, and shopping bags, and established an 
evaluation process for suppliers making environmental marketing claims on product 
labels. A year later, Home Depot discontinued sale of lead plumbing solder, and pub¬ 
lished its first version of Environmental Greenprint R , which pinpoints 88 ways to bring 
about a “greener” home in making home improvements. Home Depot also began a 
program to recycle gypsum wallboard shipping packaging, with the goal of eliminat¬ 
ing an additional 10 percent of all solid waste. The program became the first reverse 
distribution effort in the hardware industry, as material was returned to the store for 
return to the manufacturers. 

By 1993, Home Depot stores were featuring permanent banners on their front walls, 
pledging commitment to continually improve environmental performance, commu¬ 
nity involvement, and social responsibility. The first of many Recycling Depots was 
opened on a one-acre site next to the Duluth, Georgia store, integrating shopping with 
a drive-thru recycling center. Another first was the “Environmental Report Card,” 
which offered consumers a comprehensive disclosure of a product’s environmental 
impacts on its label, based on the findings of a “cradle-to-grave” life-cycle assess¬ 
ment of the product. 

In 1994, Home Depot became the first home center to offer both tropical and temper¬ 
ate region wood products from forests independently certified as “Well-Managed” 
under Scientific Certification System’s Forest Conservation Program. Home Depot 
led the industry in the changeover of interior doors to simulated wood from tropical 
rainforest wood. The company also implemented a program to replace all wood ship¬ 
ping pallets with returnable and reusable “slip sheets,” with the goal of minimizing 
solid waste and reducing energy used in transportation and consumption of hardwood 
resources used to make wood pallets. 

Home Depot’s environmental efforts were recognized in March 1995 with the 
President’s Sustainable Development Award, which noted that “by disseminating ac¬ 
curate consumer information through eco-labeling, the program has built support for 
more sustainable product design and production policies.” 

Helping Small Businesses to Undertake 
Pollution Prevention Measures 

The dynamics of preventing pollution can be different for small business compared to 
large businesses. With managers closer to day-to-day operations, pollution preven¬ 
tion opportunities may be easier to identify in small businesses. On the other hand, 


57 


Chapter 2 - Industry 


Table 2-4. Technical Assistance and Business Development Programs 

EPA’s Small Business Ombudsman 

EPA’s Small Business Ombudsman assists small businesses in complying with environmental regulations. Contact 
Karen V. Brown, 800-368-5888 with questions or concerns. The Small Business Ombudsman’s Office also coor¬ 
dinates a network of state small business ombudsmen. 

NIST’s Manufacturing Extension Partnership 

The National Institute of Standards and Technology (NIST) established the Manufacturing Extension Partnership 
(MEP) to increase the global competitiveness of smaller manufacturers. For general information, contact MEP at 
301-975-5020. (See Chapter 3, Other Federal Agencies). 

SBA’s Small Business Development Centers 

The U.S. Small Business Administration (SBA) supports 57 state and territorial Small Business Development 
Centers (SBDCs), along with over 900 sub-centers, to provide management and technical assistance to small 
businesses. EPA and SBA are developing a coordinated offering of business development and pollution preven¬ 
tion technical assistance services through five pilot SBDC projects (in Iowa, Texas, Vermont, Virginia, and Wis¬ 
consin). To locate the nearest SBDC, contact the Association of Small Business Development Centers at 703- 
448-6124. 

State Technical Assistance Programs 

Every state has a small business assistance program which, at a minimum, aids small businesses impacted by air 
quality regulations, as required by the Federal CAA. These programs are coordinated nationally from EPA’s 
offices in Research Triangle Park, North Carolina (919-541-0800). EPA also supports a broader role of state 
technical assistance programs through the Pollution Prevention Incentives for States program mandated by the 
Pollution Prevention Act. 

EPA’s Small Business Compliance Assistance Centers 

EPA recently established national Compliance Assistance Centers to provide “one-stop shopping” for information 
about complying with environmental regulations. Each Compliance Assistance Center provides some or all of the 
following services via the Internet and toll-free telephone: easy access to federal regulations, interpretations, and 
guidance; compliance tools and process-specific training; information exchange through “chat rooms” and confer¬ 
ences; and databases of technologies and pollution prevention ideas. Currently, there are four Compliance Assis¬ 
tance Centers covering agriculture, metal finishing, printing, and the automotive service industry. Four more are 
on the way, in the areas of transportation, local governments, small chemical manufacturers, and printed wiring 
board manufacturers. The existing centers can be reached at: printing — http://www.pneac.org; automotive — 
1-888-GRN-LINK (476-5465) or http://www.ccar-greenlink.org; agriculture: http://www.es.inel.gov/oeca/ag/ 
aghmpg.html; metal finishing — 1-800-AT-NMFRC or http://www.nmfrc.org. For general information, contact 
EPA’s Office of Compliance at 202-564-2280. 


58 


Chapter 2 - Industry 


very small businesses generally have few in-house technical resources and may have 
financial challenges to overcome, such as small capital budgets and difficulty obtain¬ 
ing credit. 

Over the past several years, a patchwork of state and local government and not-for- 
profit financial assistance programs, which target environmental compliance and/or 
pollution prevention activities, primarily by small businesses, has emerged (see Table 
2-4). 24 This proliferation seems to indicate that financing is the primary challenge 
small businesses face in implementing pollution prevention. A recent pilot project 
carried out for EPA by the Maryland Department of the Environment, however, sug¬ 
gests that financing is only one of a number of factors that influence pollution pre¬ 
vention decisions by small businesses. 

The pilot project, which was designed to assess whether small businesses are able to 
obtain credit for capital investments in pollution prevention, focused on 800 dry 
cleaners, 77 of which were required to retrofit their machines or purchase new ones 
in order to comply with a federal air toxics rule. The cost of the retrofit was esti¬ 
mated in the rule at $6,300, but due to the sudden increase in demand, the cost 
escalated to $15,000 within two months of publication of the rule. 

Contrary to expectations, the banks contacted as part of the project were interested in 
potential revenue associated with purchase of the new equipment, and were not con¬ 
cerned with environmental liabilities associated with the dry cleaning industry. De¬ 
spite the small size of the loans, the banks were willing to make the loans as long as an 
intermediary organization (in this case, Maryland’s Small Business Development Cen¬ 
ter [SBDC]) had analyzed the financial status of these businesses and could show that 
each would be able to meet the loan payments. One of the project’s conclusions, 
however, was that merely having a financial assistance program available does not 
ensure that it will be used. The Maryland companies that ultimately took advantage of 
the assistance available did so only after an active outreach program identified and 
encouraged them to pursue the opportunities. 25 

Some small businesses are successful in implementing pollution prevention measures, 
saving money or building markets along the way. Here are five examples: 


24 This is not an exhaustive list of technical assistance programs for small businesses. Readers 
interested in pursuing this are encouraged to refer to EPA's Pollution Prevention Directory , available 
through the Pollution Prevention Information Clearinghouse at 202-260-1023. 

25 For more information, contact Liz Taddeo, Maryland Department of the Environment, 410-631- 
4119, or Ed Weiler, EPA, 202-260-2996. Two related reports are: (1) Perkins, S.P., T. Goldberg, and E. 
Weiler. “Myths and Realities of P2 Financing,” Pollution Prevention Review (VII:2, Spring 1997) and 
(2) Great Lakes Environmental Finance Center. An Inventory and Assessment of Pollution Control 
and Prevention Financing Programs (Draft) (February 1997). Contact Ms. Ziona Austrian at 216- 
687-3988. 


59 



Chapter 2 - Industry 


Ocean State Power (Burrillville, Rhode Island) 

Ocean State Power was selected as a pilot project in EPA’s Environmental Leadership 
Program. 26 This facility, which employs 100 people, is a 500 megawatt, natural gas- 
fired, combined cycle electric generation facility located in rural Burrillville, Rhode 
Island. It was the first power plant in New England to use natural gas as its primary 
fuel. The state-of-the-art facility was designed with pollution prevention in mind. 
Ocean State Power has made significant progress on two waste reduction activities: 

■ Eliminating the oil waste created from test firing. The plant performs test oil 
firing on the turbines for 15 minutes each week. If ignition does not occur 
within the programmed time, the unit automatically shuts down and the oil has 
to be purged from the system to allow for a clean refiring. In the past, the 
plant disposed of this oil as waste. It now recycles the oil back into the oil 
tank for reuse. 

■ Reviewing a method to eliminate ammonia waste. The trucks that deliver 
ammonia to the plant do not have a method to capture the liquid remaining in 
the truck’s hose after a delivery. Currently, several gallons of ammonia are 
collected and disposed of as waste product. Ocean State Power is evaluating a 
system to pump this product into the on-site ammonia tank, thus eliminating 
the waste. 

Ecoprint (Silver Spring, Maryland) 

Ecoprint is a printer based in Silver Spring, Maryland, with fewer than 10 employees. 
Ecoprint’s clientele includes associations, environmental groups, and nonprofit orga¬ 
nizations from the greater Washington, DC area. The emphasis of their work is on 
newsletters, other publications, brochures, and some short-run direct mail. 27 Ecoprint 
has become recognized by its industry colleagues and others as a leader in environ¬ 
mentally responsible printing. Going beyond compliance with environmental laws, 
Ecoprint has spent years doing research with ink manufacturers and paper mills to 
produce new products and processes that create a higher standard of environmental 
excellence. Some of its pollution prevention achievements include the following: 

■ Developed sheetfed offset printing inks based on non-heavy metal pigments. 
New non-heavy metal inks, developed by Alden & Ott Inks, were formulated 
from a soybean oil, non-petroleum base. This was done through a 1992 
$25,000 EPA pollution prevention grant. 

■ Worked with Cross Pointe Paper Company to test a chlorine-free sheet 
combined with 20 percent post-consumer waste content. The new sheet was so 
successful that Cross Pointe invested the resources to make it a new product 
line. 


26 For more information on the Environmental Leadership Program, see Chapter 1 of this report. 

27 Ecoprint. Environmental Initiatives Fact Sheet. 


60 



Chapter 2 - Industry 


■ Eliminated alcohol and alcohol substitutes in press wetting agents. A com¬ 
pound based on non-toxic citric acid and gum arabic is now used in place of 
the alcohol. 

Frost Paint and Oil (Minneapolis, Minnesota) 

Frost Paint and Oil, which employs 35 people, is a manufacturer of industrial paints 
and linseed oil-based varnishes. 28 A few years ago, Frost Paint and Oil reviewed its 
waste streams, including paint sludge, varnish oil sludge, process water, and non- 
hazardous solid waste, and established a goal of reducing them 10 to 15 percent a 
year for 3 to 5 years. This goal was set in accordance with the Minnesota 50 Project, 
a voluntary pollution prevention program modelled after EPA’s 33/50 Program that 
Frost Paint and Oil had joined. After evaluating a number of options for reducing 
waste, the company decided that the quickest and least expensive way to reduce 
waste generation was to implement an employee incentive program. The employees 
were motivated by the promise that two-thirds of any resulting savings would be 
passed on to them. As a result of the employee incentive program, Frost Paint and Oil 
reached its Minnesota 50 Project goal in one year. The innovative approach reduced 
hazardous waste by 55 percent and saved the company $25,000 in 1992. In 1993, the 
employee incentive program resulted in a further reduction in hazardous waste genera¬ 
tion of 22 percent. During these years of dramatic waste reduction, Frost Paint and 
Oil’s production rate remained fairly constant. 

Nachi Technology, Inc. (Greenwood, Indiana) 

Nachi Technology employs 80 people in manufacturing precision ball bearings for 
the automotive industry. 29 To prepare the bearings for further processing, they must be 
cleaned to remove any contaminants. Nachi replaced its 1,1,1-trichloroethane-based 
cleaning system with machines that use centrifugal force to remove the contaminants; 
this project was not merely a solvent substitution, but a solvent elimination. The me¬ 
chanical cleaning machines eliminated 1,1,1-trichloroethane from this and all other 
manufacturing processes, which will benefit Nachi employees and the environment for 
years to come. Nachi Technology received two Indianan Governor’s Awards in 1996: 
one pollution prevention award for the solvent elimination and one recycling award 
for reducing and reusing packaging materials. 

Genencor (Rochester, New York) 

Genencor is a company with 1,200 employees that supplies enzymes and other 
biochemicals to industries. Genencor developed an environmentally friendly pro- 


28 Most of the activity in this waste reduction program was undertaken a few years ago. The company 
has since acquired another small paint company and has been renamed “Davis Frost.” In total, the new 
company has slightly less than 100 employees. 

29 State of Indiana List of 1996 Governor’s Awards for Excellence in Pollution Prevention. Indiana 
Department of Environmental Management, 317-232-8603. 


61 




Chapter 2 - Industry 


cess for manufacturing indigo dye, which is used to color blue jeans among other 
things, using biotechnology. Genencor’s process uses an intergeneric microorgan¬ 
ism, glucose, and other microbial nutrients instead of hazardous reagents like aniline, 
formaldehyde, and hydrocyanic acid. Eliminating the use of such hazardous chemi¬ 
cal feedstocks reduces exposures, releases, and risks traditionally associated with the 
manufacturing process. Genencor was recognized by OPPT’s New Chemicals Pollu¬ 
tion Prevention Recognition Project for this innovative work. 30 

Encouraging Industry-Wide Initiatives 

A positive step forward in encouraging industry initiatives in recent years has been 
the development of industry-wide pollution prevention programs by professional and 
trade associations. Such programs institutionalize the ethic of pollution prevention, 
disseminate information on an ongoing basis, and help spur individual company 
members on to more active and effective pollution prevention programs. This sec¬ 
tion highlights several such initiatives. 

In recognition of the expanding role of trade associations in helping industries in meet¬ 
ing environmental goals, EPA has sponsored the Pollution Prevention Trade Associa¬ 
tion Workgroup to bring together representatives from disparate industries. The 
workgroup develops tools to help trade associations promote pollution prevention in 
their member industries, facilitates communication and information sharing between 
EPA and trade associations, and showcases successful pollution prevention case stud¬ 
ies with broad applicability. 31 

Another organization with a similar mission, the American Institute for Pollution Pre¬ 
vention (AIPP), is a non-profit organization of professional and trade associations that 
facilitates effective communication and promotes emerging pollution prevention ini¬ 
tiatives, opportunities, and practices. 32 The Business Roundtable’s Industrial Pollu¬ 
tion Prevention Council also seeks projects to champion preventive approaches. 

Several industries have started their own umbrella pollution prevention organiza¬ 
tions. STEP, or Strategies for Today’s Environmental Partnership, was created by the 
American Petroleum Institute in 1990 as a structure for measuring and reporting cor¬ 
porate progress in the areas of environment, health, and safety. 33 

The Chemical Manufacturers Association (CMA) sponsors the Responsible Care 
program, which assists member companies in achieving a Code of Management 
Practices. Companies report implementation progress to CMA annually, in ad- 


30 For more information about OPPT’s New Chemicals Pollution Prevention Recognition Project, 
contact Ken Moss (202-260-3395) or Roy Seidenstein (202-260-2252) of EPA/OPPT. 

31 For more information on the Pollution Prevention Trade Association Workgroup, contact Leah 
Yasenchak, EPA, at 202-260-7854. 

32 AIPP Internet site (http://www.es.inel.gov/aipp/) 

33 STEP Internet site (http://www.api.org/step/ovintro.html) 


62 



Chapter 2 - Industry 


dition to conducting regular regional meetings among senior industry represen¬ 
tatives to exchange information. 34 

CMA member companies must make continuous good-faith efforts to attain the goals 
of the various codes: 

1. The Pollution Prevention Code commits industry to the safe management 
and reduction of wastes. 

2. The Community Awareness and Emergency Response Code promotes 
emergency response planning and encourages dialogue with plant com¬ 
munities. 

3. The Distribution Code focuses on employee and public risks from the 
shipment of chemicals, and applies to the transportation, storage, handling, 
transfer and repackaging of chemicals in transit. 

4. The Product Stewardship Code manages chemicals from initial research 
through recycling and disposal. 

5. The Employee Health and Safety Code protects employees and visitors at 
plant sites. 

6. The Process Safety Code is designed to prevent incidents and accidental 
chemical releases at plant sites. 35 

Northeast Business Environmental Network 

Established in 1994, the Northeast Business Environmental Network (NBEN) is an 
example of companies creating their own self-help network to promote pollution pre¬ 
vention among the businesses of their local communities. NBEN’s members range 
from large companies such as Raytheon and Gillette to small “mom and pop” print 
shops and jewelers. Each company joining the network makes an explicit, long-term 
commitment to seek and implement solutions that promote pollution prevention within 
their own business communities. The network is self-supporting through the dues of 
its members and holds monthly meetings. 

NBEN grew out of the Merrimack Project, a demonstration project developed under 
EPA’s Industrial Pollution Prevention Project. Its function is to provide a forum in 
which members can communicate with government and environmental advocates, as 
well as share pollution prevention information. NBEN currently has 53 members 
and is sponsoring workshops on watershed tools as well as Best Management Prac¬ 
tices, on the Internet. 


34 CMA Internet site (http://es.inel.gov/program/regionaI/trade/crna-rprt html) 

35 CMA Responsible Care Homepage (http://www.cmahq.com/rescare.html) 


63 




Chapter 2 - Industry 


American Textile Manufacturers Institute 

The American Textile Manufacturers Institute (ATMI) is a national trade association 
for the domestic textile industry. Member companies process approximately 80 per¬ 
cent of all textile fibers consumed by mills in the United States. ATMI launched the 
Encouraging Environmental Excellence (E3) program in March 1992 to demon¬ 
strate an industry-wide commitment to environmental preservation and strategies for 
new environmentally friendly manufacturing processes and products. E3, a volun¬ 
tary program, calls for textile companies to adopt a 10-point plan, which includes a 
corporate environmental policy statement, a detailed audit of facilities, an outreach 
program to suppliers and customers that encourages pollution prevention, recycling, 
establishment of corporate environmental goals, and the development of employee 
education and community awareness programs. Specifically, the program calls on 
companies to establish annual pollution prevention goals and target dates for air, 
water, solid waste, and energy. Each company must report annually on its successes 
and failures in achieving its goals. 36 ATMI was recognized in 1996 for its efforts 
to promote the WasteWi$e program and encourage waste reduction among its 
membership. 

In 1994, several companies participating in the E3 program recorded accomplishments 
in achieving their pollution prevention goals. For instance, Burlington’s Denim Divi¬ 
sion made some changes in the dyeing and finishing chemicals it uses (i.e., elimination 
of free sulfurs in dyeing, reduction of indigo and dye with a sulfur odor). Other manu¬ 
facturers developed new environmental product lines, such as Avondale Mills and 
Doran Textiles, which are offering organically grown, naturally colored cotton spe¬ 
cialty apparel lines. 37 

Great Printers Project 

In 1992, EPA received a request for assistance in evaluating product environmental 
claims from the Printing Industries of America (PIA). Through the involvement of 
EPA’s Design for Environment (DfE) Program, two pollution prevention projects 
evolved. Each project was directed towards a different aspect of the printing industry: 
the screen printing sector and the lithography sector. The Screenprinting and Graphic 
Imaging Association played an important role in the development of the DfE Screen 
Printing Project. 38 

In August 1993, a cooperative effort called the Great Printers Project was launched 
to make pollution prevention a standard business practice in the entire printing in- 


36 American Textiles Manufacturers Institute. America s Textiles: Encouraging Environmental 
Excellence. 

37 American Textiles Manufacturers Institute. ATMI speech at the Green Business Conference (April 7, 
1995). 

38 EPA. "Enviro$en$e DIE Fact Sheet: Screen Printing Project on Designing Solutions for Screen 
Printers" (EPA 744-F-95-003, March 1995). 


64 



Chapter 2 - Industry 


dustry. The project is a partnership of the PIA, the Environmental Defense Fund 
(EDF), and the Council of Great Lakes Governors. A project team of Great Lakes 
regulatory agencies, EPA, printers, print buyers, printing industry suppliers, techni¬ 
cal assistance providers, environmentalists, and labor are implementing recommen¬ 
dations to prevent pollution and waste from solvents used in cleaning, waste ink, and 
photoprocessing materials, while enhancing industry growth. 39 For example, in 1995, 
with funding from EPA, the Great Printers Project launched the Printers National Envi¬ 
ronmental Assistance Center in 1995 as a small business compliance assistance center. 

Reaching Suppliers and Customers 

One way to reach out to customers is by enacting a product stewardship program. The 
term “product stewardship” refers to practices where manufacturers essentially be¬ 
come stewards of industrial products by retaining responsibility for their products un¬ 
til those products reach the end of their life or are reused. Product stewardship prac¬ 
tices are increasingly common in industry for a number of reasons, not the least of 
which is minimizing environmental liability. Key to the development of product stew¬ 
ardship programs is the realization that suppliers and customers are integral links in 
the life cycle environmental impacts of a company’s products. 

In this section, we provide some successful examples of companies that have worked 
with their suppliers and customers in preventing pollution. 

Digital Electronics 

In recent years, the computer industry has developed a reuse and recycling program 
worthy of mention for its originality in coupling a unique customer service with 
pollution prevention. As an example of a firm which practices this recycling ser¬ 
vice, consider Digital Electronics. Digital’s “Computer Asset Recovery Service” is a 
prime example of a corporation extending the life cycle of a product. Because of the 
fast-paced innovation in computer technology today, computer users tend to replace 
their equipment frequently. This used to mean that they threw away their computers 
frequently. Today, Digital’s commercial customers can return their used computers to 
Digital, which assumes “ownership” of the aging or obsolete computer equipment, 
meaning that it accepts liability for the material under the Resource Conservation 
and Recovery Act (RCRA). RCRA stipulates that if a discarded material causes 
problems in a landfill and the ownership can be traced, then the owner of the waste is 
responsible for the problem and its consequential cleanup. By assuming ownership. 
Digital Electronics assists its customers in preventing the disposal of hazardous com¬ 
puter materials. 40 


39 EPA, “Great Printers Project Announced,” Pollution Prevention News (September/October 1993). 

40 Norm Alstar. “Old PCS Are ‘Liability Scrap’, But Digital Sees Opportunity,” Investor’s Business 
Daily (November 6, 1995). 


65 







Chapter 2 - Industry 


Once the older equipment is in Digital’s hands, the company attempts to sell second¬ 
hand any computers or computer parts that are in decent working order. The com¬ 
puter equipment left over from this process are “demanufactured” — the pieces 
are broken down into the most basic elements (mercury, gold, steel, aluminum, 
glass, and plastic) and then recycled. The remaining waste, totaling approxi¬ 
mately one-half of one percent of the original, is properly disposed of in a land¬ 
fill. Digital Electronics shares the profits from the selling and recycling pro¬ 
cesses with clients, creating a “win-win” arrangement for both parties, as well as 
reducing the toxic load on the environment. 41 

Walt Disney Company 

Purchasing agents at the Walt Disney Company have gone on record with vendors and 
suppliers that the company “insists whenever possible” upon purchasing products 
and services that are environmentally appropriate. This policy has manifested itself 
in everything from the purchasing of bulk food products to printing millions of bro¬ 
chures, pamphlets, maps, and other documents on recycled paper. The company 
believes that in some cases it has actually driven the market, not only towards the use 
of recycled material, but also towards packaging and product minimization. One 
outgrowth of Disney’s environmental purchasing policy is the replacement of Lauan 
plywood, a product derived from tropical rainforests, with a product made from waste 
wood. The Walt Disney Company was recognized in 1996 by the WasteWi$e Program 
for its Comprehensive Waste Reduction Program. 

Because Disney is a leader in the entertainment field aimed at young people, it has a 
unique opportunity to foster an environmental conscience in its young customers. For 
example, the Walt Disney Studio works with the Environmental Media Association in 
an effort to include environmental messages in film and television programming. 
These messages have appeared in episodes of the Golden Girls, public service an¬ 
nouncements entitled Disney's Magical Moments, Medicine Man, the award winning 
This Island Earth, Dinosaurs, and, more recently, Disney presents Bill Nye the Sci¬ 
ence Guy. 

Other environmental education projects managed by the Walt Disney Company in¬ 
clude the following: 

■ Developing, together with several participating agencies and organizations, a 
community program to introduce urban youth, ranging in age from 8 to 12, to 
a neighborhood camping experience. The program will kick off at City of Los 
Angeles parks and will include programs in wildlife observation, environmen¬ 
tal resources, community service, and introductory camping. 


41 Digital Equipment Corporation. “GSA Selects Digital for the Environmentally Safe Disposal of 
Government Equipment,” Digital Press and Analysts News (July 12, 1996). 


66 



Chapter 2 - Industry 



■ Jiminy Cricket’s Environmentality Challenge Program. This cooperative 
learning venture promotes environmental education to all fifth grade classes in 
California public schools. The challenge recognizes and honors those students 
and teachers who demonstrate the leadership, creativity, and dedication needed 
to promote thinking and acting environmentally. 42 

Donlar Corporation 

Donlar Corporation has developed a product that embraces the product stewardship 
ideal. The company manufactures thermal polyaspartate (TPA), a biodegradable al¬ 
ternative to the polymer polyacrylic acid (PAC). Two manufacturing processes are 
used to make TPA. The first process, a two-step system, is 97 percent efficient and 
produces condensated water as its only waste stream. The second method uses a 
recoverable catalyst, which minimizes the amount of created waste. These manufac¬ 
turing processes are excellent examples of pollution prevention in industrial design. 

TPA’s end uses exemplify the concept of product stewardship. In the agricultural 
sector, it improves fertilizer management by increasing plant nutrient uptake, yet 
does not place an additional burden on the ecology of the land. It can also be used as 
an alternative to PAC in the water treatment industry as well as the oil and gas 
production industry, due to its scale and corrosion-inhibiting properties. 

The designers of this polymer integrated pollution prevention into every aspect of 
their product, and were duly rewarded with the Presidential Green Chemistry Chal¬ 
lenge Award. 43 

Making the Most of Community 
Involvement 

Sue Hall of Strategic Environmental Associates has argued that market restructuring 
offers businesses a rather stark choice: 

They can choose to deny the reality and continue with business as usual, 
rather than innovating to create more sustainable products and services. 

In this case, their businesses will continue to cause environmental prob¬ 
lems, fueling the market restructuring and ultimately creating a down¬ 
ward competitive spiral for the company. Or, a company can decide to 
learn from others ... in order to create more sustainable products for its 
core businesses. 44 


42 The Walt Disney Company. “The Walt Disney Company Environmentally Significant Activities”. 

43 EPA. The Presidential Green Chemistry Challenge Awards Program: Summary of 1996 Award 
Entries and Recipients. (EPA744-K-96-001, July 1996.) pp.5-6. 

44 Sue Hall. “Sustainable Partnerships” In Context: Business on a Small Planet (No. 41, Summer 
1995). 


67 






Chapter 2 - Industry 


The following are examples of companies that are working with and learning from 
their communities and stakeholders. 

Church & Dwight 

Church & Dwight is one example of a company that has gained considerable market 
share by working with its environmentally-conscious stakeholders. Church & Dwight 
is the maker of Arm & Hammer baking soda. Church & Dwight’s interest was 
piqued when members of Canadian environmental groups asked the company why it 
was not educating consumers about baking soda’s use as an alternative, non-toxic 
cleaner. Three years later, baking soda sales had risen 30 percent, in an industry in 
which sales had been stagnant for decades. After this experience. Church & Dwight 
began to deepen relationships with stakeholders — including environmental groups, 
educators, the media, and regulators. The company patented a new product line of 
industrial cleaners following suggestions from stakeholders that Church & Dwight 
investigate baking soda as a replacement for the toxic solvents used to clean printed 
circuit boards. An analysis of the usefulness of the stakeholder approach from a 
financial perspective found that the company’s stakeholder process added $10 to the 
top line for every dollar invested in it — as opposed to $4 for a traditional marketing 
program. 45 

Ciba-Geigy (San Gabriel, Louisiana) 

The Ciba-Geigy San Gabriel plant is a highly automated chemical process complex 
operated by Ciba’s Crop Protection Division. The continuous herbicide production 
process at San Gabriel produces more herbicides than any other manufacturing plant 
in the United States. In addition, the Textile Products Division operates a multipur¬ 
pose dyestuffs facility on the site. This facility has developed an extensive community 
and employee outreach program. For eight years, the facility has conducted a survey 
of East Iberville Parish residents asking general and specific questions on local prob¬ 
lems, pollution, employment, emergency response, education, public perception, etc. 
The facility also has developed a series of community outreach programs — a Citizen’s 
Advisory Panel, a community newsletter, an Odor Response Program, and a Summer 
Teachers Program. A Ciba Ambassadors Program addresses employees’ environmen¬ 
tal concerns, and trains and encourages employees to answer questions on environ¬ 
mental issues, including pollution prevention and waste management. 

The San Gabriel plant is conducting a pilot project under EPA’s Environmental Lead¬ 
ership Program in which it will evaluate its community involvement program and 
identify the program elements other companies may include in their environmental 
education and outreach programs to build trusting relationships. 


68 


45 Ibid. 



Chapter 2 - Industry 


Selling Environmentally-Preferable Products 

Years ago, product labels rarely provided more information than the brand name of 
the product. Today, grocery store customers walk down aisles turning product pack¬ 
ages upside-down looking for nutritional information. Increasingly, these customers 
will be doing the same looking for information on a product’s environment impacts — 
ranging from toxic chemical effects on health to energy use to recycling and 
disposal. 46 

The question of what makes a product “greener” or environmentally more preferable 
to another is a source of much debate and legitimate confusion. Some pollution 
prevention practitioners have found that the complicated practice of life cycle assess¬ 
ment can highlight environmental tradeoffs associated with products. Life cycle 
assessment is a technique for assessing the various environmental impacts associated 
with a product. The assessment involves taking an inventory of environmental ef¬ 
fects during the various stages of a product’s “life cycle” — from use of raw materials 
such as energy, minerals, or water, to packaging to waste management — and then 
assessing the impacts of these inventoried effects. Whether life cycle assessment can 
be developed to the point that it can serve as a practical guide to determining the 
overall environmental preferability of products is as yet unclear. In the meantime, 
two independent organizations. Green Seal and Scientific Certification Systems, have 
built businesses judging environmental attributes of products and allowing those 
judgements to be displayed on product labels. 

While debate continues over what makes a product “green”, it seems that an increas¬ 
ing number of consumers are taking environmental considerations into account when 
they shop. A recent survey found that the environmental record of a company ranks 
as an important factor in brand choice for 14 percent of American consumers, behind 
brand loyalty, price, quality reputation, and how well the product is advertised. 47 
One industry analyst interprets these findings to indicate that environmental benefits 
represent second-tier purchase criteria, which can break ties in purchase decisions 
when brands are at price/quality parity. 48 Increasingly, it appears, companies are 
responding to this market force. The following are several examples of this trend: 

The Henkel Company 

The Henkel Company is one of Europe’s largest chemicals and detergents compa¬ 
nies. In the late 1970s, Henkel began to notice a rising concern in West Germany 
surrounding the potential impact of phosphates in detergents on rivers and streams. 


46 See Chapters One and Three of this report for a discussion of how federal consumers are applying 
their purchasing power to create a demand for products and services that have a reduced impact on the 
environment. 

47 Roper-Starch survey. 

48 Personal conversation with Frank Consoli, President and Founder of the Consoli Consulting 
Company and a leader in the field of life cycle assessment, March 1996. 


69 




Chapter 2 - Industry 


At the time, Henkel manufactured 50 percent of the country’s phosphates and sold 49 
percent of its phosphate-based detergents. Instead of attempting to downplay the 
problem, Henkel decided to invest in finding a substitute for phosphates. The 
company’s search for a substitute was successful; it patented zeolite and became 
the first consumer products company to introduce phosphate-free detergents in 
Europe, entirely replacing all its old product lines. As a result, the company in¬ 
creased its market share from 16 percent to 23 percent for its top brand in Germany 
and strengthened its foothold in the French market, gaining a 6 percent share for its 
new phosphate-free brand. 49 

Wellman, Inc. 

Wellman, Inc., one of the largest plastics recycling companies in the world, was able to 
gear its services towards the future by creating a market for PET, a recyclable plastic. 
Initially, the company teamed up with bottle producers, such as CocaCola and Pepsi 
Co. (Pepsi Cola Bottling Company), to provide recycling for the plastics they had 
been accumulating from Bottle Bill states. 50 By tapping into this demand for recy¬ 
cling, Wellman sustained a 40 percent growth rate and a 21 percent return on equity 
over a 6-year period. Once Wellman’s recycling competitors began to vie for a share 
of this market, Wellman again thought ahead and expanded the business to include an 
outlet for the recycled PET plastic: the synthetic fiber industry. This action not only 
opened up a wider customer base for Wellman, but also allowed consumers the choice 
of buying products containing recycled plastic. 

Miles, Inc. 

The Miles, Inc. company, based in Pittsburgh, Pennsylvania, has developed a polyure¬ 
thane paint that allows repainting of bridges and other steel structures without the 
need for hazardous abrasive blasting operations to remove toxic lead-based paint. 
The benefits of this new paint include reduced occupational exposure to lead, less 
environmental contamination, and less generation of hazardous waste. In addition, 
with less surface preparation required, companies that repaint bridges considerably 
reduce costs. This innovation also gave Miles a unique competitive advantage in 
projects involving state highway departments and their contractors at a time when 
regulations affecting bridge repainting were on the horizon. 51 


49 Sue Hall, “Sustainable Partnership.” In Context: Business on a Small Planet (No. 41, Summer 
1995). 

50 The Bottle Bill requires states that pass this legislation to have beverage vendors be responsible for 
their containers, once the consumer turns the container in for a rebate. 

51 Young, Ambrose, and Lobo, Stirring Up Innovation: Environmental Improvements in Paints and 
Adhesives (INFORM, New York, NY, 1994). 


70 





Chapter 2 - Industry 


Innovative Ideas 

To conclude this chapter, we present a list of innovative ideas that industry has devel¬ 
oped in recent years to promote pollution prevention. The usual disclaimers apply 
— not all of these ideas will storm the marketplace, some may already be obsolete, 
and EPA does not endorse any commercial products. But the range of possibilities 
and achievements cited here in terms of new and cleaner processes, products, and 
technologies is worthy of note. 

Conserving Water by Changing Services 

Developed by: Harrah’s Hotel and Casino, Las Vegas, NV 

The idea: Allow customers who stay more than one night to decide whether or not they 
want their sheets changed daily. Previously, it had been the hotel’s standard operat¬ 
ing procedure to change and wash 1800 sets of sheets every day, assuming that cus¬ 
tomers wanted this service. The energy management team developed a flyer which 
stated the hotel’s environmental policy and notified guests that if they still wanted 
their linens changed daily, they should call and request it. In response, the majority 
of guests opted not to have their linens changed daily. This change in hotel policy 
saved the hotel $70,000 in energy and water costs the first year, as well as reducing 
the pollutant loading at the wastewater treatment plant and increasing the longevity 
of the sheets. 52 

Cost Reduction through Solvent Substitution 

Developed by: Martin Marietta’s Astronautics Group, Denver, CO 

The idea: Phase-out the use of two chlorinated solvents and a toxic chemical used in 
hand-cleaning operations. The group first substituted Daraclean 282 for 1,1,1- 
trichloroethane, which was used for rocket component degreasing. After incurring 
$270,000 in up-front costs, the company saved $600,000 annually. Additional bo¬ 
nuses are the increased cleaning ability and the recyclable characteristic of the new 
solvent. The next solvent to be eliminated was CFC-113, which was used to clean 
spacecraft components. The replacement was an alcohol-based spray that saved the 
company $325,000 a year, with a payback period of 4 years (the start-up costs were 
$1.3 million). The last solvent changed was a toxic chemical used to clean alumi¬ 
num before adhesive bonding occurred. The switch to a citrus-based solvent saved the 
company $250,000 annually, reduced toxic emissions by thousands of pounds, and 
improved worker satisfaction — it smelled more pleasant and worked better than the 
old solvent. 53 


52 Romm, Joseph J. Dan and Clean Management. (Kodansha International. New York, NY, 1994). 


53 Ibid. 


71 





Chapter 2 - Industry 


The Cascade Approach for Water Conservation 

Developed by: Buckeye Cellulose Corporation, Flint River Plant, MI 

The idea: Use a cascade approach for water, in which it is routed “through processes 
requiring the purest water to those requiring successively less pure water.” This 
process change reduced the plant’s demand on the municipality’s water resources 
and reduced the amount of wastewater requiring treatment. The company also al¬ 
tered their method for transporting reject wood scraps. Instead of using water to 
transport the wood scraps to a press and ultimately landfilling the waste, there is now 
a closed-loop system for refining and recycling the rejects. This process change 
reduces the amount of wood being landfilled and reduces the biological oxygen de¬ 
mand (BOD) in the water used for transport. Previously, water used to transport wood 
rejects incurred a high BOD from microbial activity from the wood itself. The BOD 
loading in the water made the water increasingly difficult to treat at the wastewater 
treatment facility. With a closed-loop system, Buckeye was able to reduce BOD in 
their wastewater to one of the lowest levels in the industry. 54 

Environmental Reengineering in the Citrus Industry 

Developed by: Regal Fruit Co-op, Tonasket, WA 

The idea: Examine the energy use of its fruit storerooms, which store produce at 31° 
to 32° F in an almost pure nitrogen environment, with fans running continually. 
Upon further investigation, it was discovered that the cooling system was counteract¬ 
ing heat produced by the fans. By installing a computer-controlled monitoring system, 
the fans would run 75 percent less and create much less heat — realizing a total energy 
savings of more than $17,000 annually. The company also realized further energy 
savings by reducing the amount of oxygen in the storeroom. Increasing the nitrogen 
level allowed for increased storage temperature (and consequently less load on the 
cooling system) as well as better quality fruit, which increased the profitability of the 
company. 55 

From Bigger to Smaller in Hazardous Waste Generation 

Developed by: Echo Bay/Cove Mine 

The idea: Reduce use of halogenated solvents by identifying solvents that were not 
considered to be Toxicity Characteristic (TC) chemicals and develop a filtration sys¬ 
tem to recycle the new solvent. The company screened all potential solvents to deter¬ 
mine those that would give an acceptable level of cleaning for parts washing, had a 
flash point above 140°F, did not have a RCRA hazardous waste code, would not oxi¬ 
dize parts, were not costly, could be filtered onsite, were easy to handle, and did not 
contain halogenated or EPA TC constituents. Although the replacement solvent was 


54 Ibid. 


72 


55 Ibid. 




Chapter 2 - Industry 


more expensive than the halogenated one, costs were not prohibitive for the company 
because the new solvent could be recycled. A filter system based on a high-flow 
pump, stainless steel screens, and a paper filter was used and had the additional 
advantage of also absorbing and reducing the heavy oils in the used solvent. This 
new system required an initial investment of $11,400, but the return on investment 
was 154 percent with a payback period of less than 18 months. Most of the annual 
savings of $9,300 was in the form of reduced solvent costs. This system not only 
reduced the toxicity of the waste but also permitted Echo Bay/Cove Mine to change 
its status from Large Quantity Generator to a Conditionally Exempt Small Quan¬ 
tity Generator with reduced regulatory requirements and environmental liability for 
a cost savings of $16,000 per year because of fewer training needs. 56 


Newspaper Recycling of Waste Ink 

Developed by: The Hartford Courant 


The idea: Purchase an ink recycling unit in order to eliminate the generation of 
hazardous waste inks and reuse the recycled ink in lithographic printing operations. 
The waste ink is collected in a storage tank, then run through the recycling unit to 
produce a reusable black ink. The recycling unit uses a vacuum distillation, filtration, 
and blending process. The reusable black ink is mixed with virgin ink to the desired 
property. The solvent present in the waste ink is recycled and, therefore, only water 
and paper-dust paste are present in the recycling wastestream, which is no longer con¬ 
sidered to be hazardous because the heavy metals and solvents are no longer present. 
The company moved from having a 12,000 lbs/year hazardous wastestream to a 1,500 
lbs/year nonhazardous wastestream. 57 

New Soldering Process for Circuit Boards 

Developed by: Motorola Government Systems and Technology Group 

The idea: Eliminate the use of chemical rinses containing ozone-depleting substances 
when preparing metals for soldering. Working with the Department of Energy, Motorola 
developed a soldering process that eliminated the need for chemical rinses after the 
use of a chemical flux to remove oxides from the metal surface. The new process 
replaces the flux with a mixture of adipic acid, a nontoxic organic acid, in isopropyl 
alcohol. The mixture is sprayed onto the circuit boards that are passed through an 
inert gas section of a wave soldering machine. This prevents oxide formation during 
the heating of the board to soldering temperatures. When the board then passes onto 
the liquid wave of solder metal, the adipic acid acts as a scavenger for the oxides. The 
only waste products of the system are carbon dioxide and water vapor. No further 
cleaning of the boards is required as no corrosive residues are formed. This process 


"Remarkably, our 
scientific team 
found a way to 
dissolve high 
performance 
vegetable oil based 
ink with a simple 
water solution. 

Now water and oil 
do mix." 

— Tom Rifkin, 
Deluxe Corporation 


55 EPA. Pollution Prevention Success Stories (EPA/742/96/002, April 1996). 

57 Ibid. 

58 Ibid. 

73 





Chapter 2 - Industry 


has eliminated the previous use of 48 tons of chlorofluorocarbons and trichloromethane 
per year. Although the new machines require a significant capital investment, con¬ 
ventional wave solder machines can be retrofitted at a much reduced cost. 58 

UV Coating to Cure Cans 

Developed by: Coors Brewing Company 

The idea: An alternative to current methods of decorating the 100 billion aluminum 
cans produced annually, which does not result in VOC emissions. The technology 
uses UV light to cure the decorative image on the exterior of aluminum beverage cans, 
rather than curing the cans in a gas-fired oven. Separate UV “fountains” supply the ink 
to rollers, which coat individual plates. The plates, one for each color used, are raised 
positive images of the graphic design to be printed on the cans. Clean cans are fed into 
the printer and placed on a rotating steel mandrel; in rotating the can body against the 
rotating blanket, the graphic image is transferred to the can. The cans are trans¬ 
ported to the UV oven for curing with UV light. Overall energy costs are signifi¬ 
cantly lower for the UV curing than for conventional thermal technology if air emis¬ 
sion controls are factored in, and fewer VOCs are emitted. 59 

Printwise™ 

Developed by: Deluxe Corporation, St. Paul, MN 

The idea: A system that eliminates petroleum-based solvents and their related VOCs 
from the lithographic printing process. These solvents, generally consisting of 100 
percent VOCs, have traditionally been used to clean ink from press components. 
The resulting “press washes” are considered by EPA to be a significant source of 
VOC emissions. The Printwise™ ink is 100 percent vegetable oil-based and matches 
or exceeds conventional inks in press and printing performance. Most important, the 
ink includes a solubility conversion mechanism that enables it to be cleaned with a 
simple, VOC-free water solution. Deluxe’s breakthrough resulted when corporate sci¬ 
entist Tom Pennaz began regarding lithography as a system in which ink and solvents 
act as interdependent, not independent, elements. Pennaz developed a solubility con¬ 
version mechanism that he incorporated into traditional ink formulations. Acting as a 
“key,” the solubility mechanism locks the oil-based Deluxe ink during printing but can 
be unlocked and converted to a water-soluble state during cleanup. As a result, 
although the Deluxe ink remains truly lithographic, it requires a water-based, VOC- 
free solution for cleanup. 60 


59 EPA. Pollution Prevention News (May-June 1995). Featured in U.S. Department of Energy’s 
Innovative Concepts Fair, April 1995. 

60 EPA, Pollution Prevention News (June-July 1994). 


74 




Chapter 2 - Industry 


Conclusions 

Six years ago, pollution prevention in industry was the province of a handful of 
leaders and visionaries, mostly in a few large corporations. That vision has spread to 
a much larger universe of firms across a wide range of industries. EPA’s early volun¬ 
tary industry programs, 33/50 and Green Lights, were instrumental in setting up a 
framework for companies to act positively and cooperatively with EPA in undertak¬ 
ing pollution prevention measures. 

Companies appear to be motivated to adopt pollution prevention innovations by a 
combination of factors. Some are attracted by perceived economic benefits, either in 
the form of cost savings or increased market share. Some respond to the threat of 
government regulation, still others to the willingness of regulators to be flexible. Some 
companies are motivated by customer demand for “green” products; others by public 
attention to their polluting practices. Thus, both the carrot and the stick seem to be 
effective for different companies. And just as responses to incentives differ, so do the 
ways in which different businesses undertake pollution prevention measures. This 
chapter has offered a glimpse of the manifold innovations and opportunities open to 
industry in pollution prevention. 

Among the challenges that lie ahead, three in particular stand out: achieving a more 
widespread use of environmental accounting to ensure that corporate management is 
fully aware of the costs of pollution and waste; disseminating information and techni¬ 
cal assistance to small and medium-sized firms in order to increase their participation 
in pollution prevention; and harnessing purchasing power of consumers to drive the 
market towards environmentally-preferable products. 


75 



Chapter 2 - Guest Commentary 


Comments on tlie Current and Future State of 
Pollution Prevention 

by 

Edwin L. Mongan 

Manager, Pollution Prevention Programs 
DuPont Safety, Health and Environment 
Wilmington, Delaware 

Mr. Mongan is also the Chair of the Business Roundtable’s Industrial Pollution Prevention Council. 

As we review environmental progress during the past decade, industry can look back with satisfaction on its 
accomplishments in reducing waste and emissions. Through practice of pollution prevention, companies have 
enhanced their relationships with local communities, improved their products for their customers, and made real 
environmental improvements. Significantly, many companies have done all of this while improving their bottom 
line business results. The positive results achieved so far are a good beginning, but much more remains to be done 
by industry in order to approach the full potential for combined business and environmental improvements. DuPont 
Chairman, Ed Woolard stated, “Our most difficult challenge continues to be eliminating waste at the source. This 
area also represents our biggest opportunity for business improvement since every pound of waste represents a 
pound of ingredient that has not ended up as a high-value product even though it should.” 

The most significant change that has occurred in industry since the Pollution Prevention Act was adopted in 1990 
is not a new system or new technology, but rather a change in attitude. There is a rapidly growing realization by 
companies that they can no longer afford to view the environment and business as two different topics, let alone 
two competing topics. Thousands of large and small companies are establishing demanding waste and emissions 
reduction goals, enlisting in voluntary programs, and publicly reporting their progress. Once they commit to a 
goal, company leaders are challenging employees to meet and exceed their public commitment in a way that saves 
both money and valuable resources. Numerous success stories have been published by the States, the EPA, and 
private organizations. They describe hundreds of innovative solutions to difficult waste problems, resulting in 
millions of dollars of cost savings and revenue increases, often for minimal or no capital investment. Sharing these 
stories has served to energize, educate and enable other companies to build on these efforts. 

The key to future success lies in cooperative efforts involving companies, local communities, regulatory agencies, 
and environmental groups. This is the best way to create needed environmental improvements while at the same 
time strengthening the competitiveness of U.S. industry in a global marketplace. Voluntary programs such as 
EPA’s 33/50 Program of waste and emissions reductions have demonstrated that outstanding environmental and 
business benefits can be achieved in a spirit of partnership and cooperation. The 33/50 Program has served as a 
valuable tool to help focus, prioritize and measure waste and emissions reduction efforts. The national attention 
accorded the 33/50 Program has helped companies like DuPont to sustain and accelerate their waste and emissions 
reduction efforts. 

National programs such as 33/50 will and should continue to play an important role in future pollution prevention 
efforts. However, increasing attention is being given to partnerships with the local community as businesses direct 
their attention to the concept of sustainable development. Through national programs and local partnerships, 
companies have made great progress in eliminating waste at the source, increasing recycling of waste and post¬ 
consumer materials, and developing products and packaging with greatly reduced environmental impacts. At 



76 






Chapter 2 - Guest Commentary 


DuPont, our ultimate objective is to operate in harmony with the community, in boundary-less plant sites where 
information, understanding, concerns and people flow freely between the plant and its surroundings. Economic 
growth, environmental protection, and strong educational systems must be addressed together as part of a vision 
of local sustainability. 

EPA can benefit both industry and communities by providing a framework and tools for setting priorities for 
future pollution prevention efforts. This must start with a sound scientific assessment of which sources of waste 
and emissions are of greatest concern to human health and the environment. Priority-setting must be done through 
an open and cooperative dialogue, with the agency, affected industry, community members, and environmental 
groups participating. An example of a current effort is EPA’s Waste Minimization National Plan, which has 
focused attention on persistent, bioaccumulative, and toxic compounds and targeted them for voluntary reduc¬ 
tions. As part of the process of developing the National Plan, stakeholder meetings involving industry, states, and 
public interest groups were held to provide opportunities for input and dialogue. 

EPA and state regulators must seek opportunities to provide industry with the flexibility to adopt pollution pre¬ 
vention solutions as alternatives to end-of-pipe controls. Two concerns are paramount: (1) provide ample time to 
investigate and implement innovative source reduction alternatives versus end-of-pipe controls, and (2) make 
regulations performance-based rather than mandating specific technologies. In some cases, new regulations are 
continuing to drive industry to invest their limited capital dollars in expensive end-of-pipe control technology. 
However, EPA’s Permits Improvement Team has offered a new paradigm for reinventing the permitting process. 
Their proposals would enable and encourage greater adoption of source reduction methods while at the same time 
offering industry the flexibility to grow and make operating changes at the rapid pace needed to succeed in a 
competitive global marketplace. 

Industry must provide the leadership and innovation to create a step change in our approach to protecting the 
environment if we are to achieve our vision of a sustainable future — a clean environment and healthy economic 
development. Industry must continue to share its accomplishments and build on the successes and learning of 
others. Communities, large and small industries, regulatory agencies, and educators must form partnerships to 
establish priorities for accelerated progress. States and federal regulators must continue to shift their emphasis 
from end-of-pipe command and control regulations to promoting pollution prevention through flexible, voluntary 
programs, information sharing and recognition of successful efforts. There is much hard work to be done, but our 
efforts will ensure positive results for ourselves and future generations. 


77 



Chapter 2 - Guest Commentary 



The Dow Chemical Company 

by 

Craig Doolittle 

Manager, Pollution Prevention Issues 
The Dow Chemical Company 
Midland, Michigan 


Industry in the 1990s is once again a focal point for environmentalism. This time, however, U.S. industry has a 
challenge to be competitive in a global market while at the same time, it has the opportunity to play a leadership 
role in advancing efforts to prevent pollution and waste. As the global marketplace rapidly expands, multinational 
businesses find themselves in a unique position to advocate and catalyze responsible and sustainable growth at 
home and overseas. While striving to balance the need for mandated environmental controls with the entreprenural 
needs of free enterprise in the United States, industry must leverage and integrate pollution prevention concepts 
across its operations and businesses globally. 

It is clear that waste cannot be tolerated in our operations if we are to stay in business in the twenty-first century. 
While this is not exactly a revelation, the idea takes on special meaning in the context of the changing and expand¬ 
ing marketplace. The new competitive business reality brings the weight of market forces to bear on environmen¬ 
tal progress. Industry can use its expertise and resources to eliminate waste and increase productivity, while 
increasing the growing demand for our products worldwide. How industry actually manages the change to more 
efficient production and use is the key to whether we will actually be sustainable. 

Industry not only has the opportunity to lead pollution prevention, we also have the motive and the tools to make 
it a reality. Our motive is simple: to survive, we must provide the lowest-cost, highest-quality products and ser¬ 
vices. Our customers expect this more than ever before. Our shareholders want increased profitability and pro¬ 
ductivity. At the same time, society calls for continuous improvements in our environmental, health and safety 
performance. How do we assure all needs are met? By using the tools at our command to make cost-effective 
pollution prevention an integral part of what we do and how we think both individually and as a corporation. 

Tools for Responsible Growth 

We have several tools to help us manage sustainable growth in a responsible manner. One such tool is standardiza¬ 
tion. We can apply the same state-of-the-art technology for manufacturing polystyrene, whether in Joliet, Illinois, 
or Map-Ta-Phut, Thailand. A network of global technology centers ensures that our sites utilize the latest innova¬ 
tions to maximize productivity and limit waste. We are also working to standardize our operating practices, to 
ensure each pound of polystyrene (or other Dow product) is made with the same attention to quality, environmental 
protection, safety and health, no matter where it’s made. 

Plant engineering and design can further drive “resource productivity,” which basically means making more with 
less. We strive to make every new plant we build the best one we have ever built in terms of both process engineer¬ 
ing, design and environmental, safety and health impacts. For example, an $800 million expansion of our site at 
Fort Saskatchewan, Alberta, Canada, includes a new closed-loop system that prevents the hydrocarbons plant 
from sending any process waste water to the nearby river. This is the first plant of its kind in the world. 


78 




Chapter 2 - Guest Commentary 


Another business tool called “activity-based costing” (ABC) also can help businesses identify areas where 
resources are being wasted. Simply put, ABC assures that all the present and future costs of making our 
products is considered in determining that product’s profitability. For example, ABC asks each business to 
factor in the future costs of production, which may include environmental considerations such as recycling, 
waste disposal, treatment or remediation of future disposal. In this way, EHS costs can be accurately incorpo¬ 
rated into the profit or loss statement for each product. This approach also supports life cycle analysis, which 
evaluates our products from design to disposal or recycling. These tools help us to be more competitive long¬ 
term in the marketplace. 

While we talk a great deal about being more competitive by reducing waste, we also realize that there are some 
cases where improvements must be made to address important environmental, health or safety issues. The best 
example of this at Dow is our emissions reduction goal for 2005. We already reduced global emissions by 50 
percent between 1988 and 1994. Further reductions to meet the new targets in our 2005 goals will require an 
estimated capital investment of about $300 million over 10 years. This investment may not generate a dollars- 
and-cents return, but it will help us address an essential part of being a successful company by meeting the 
public’s expectations for lower eimssions. 

Integrating Strategies 

The key to making some of these tough decisions is strategic integration. Companies must blend business and 
environmental management systems and decision-making in order to achieve pollution prevention goals. This 
requires a new model for business, one that merges economic and competitive reality with environmental, health 
and safety performance. Business and EHS management systems have often been managed separately. By fully 
incorporating EHS goals into business goals, product by product, corporations can make more informed decisions 
on where investments and resources are needed. Sustainbility then becomes determinable on a cost basis. 

What does the future look like? We will move further along the continuum from the end-of-pipe treatment phi¬ 
losophy of yesterday to today’s focus on pollution prevention — to tomorrow’s market mandate of “resource 
productivity.” Our businesses cannot focus on preventing pollution for its own sake. Long-term, the question we 
must ask is not simply “How can I eliminate waste from this process?” Rather, it is “how can I use less raw 
material to make more product with less waste?” When we fully integrate this thinking into our daily life, we will 
have made tremendous progress along the path to sustainable development. 

It’s one thing for the business community to talk about the opportunity and tools for merging economic and 
environmental decisions, but it’s quite another to build a regulatory system that encourages such action. Many 
of the laws and regulations with which businesses comply today are crafted according to the old command and 
control paradigm. There is often little incentive for companies to make the changes or use innovative ap¬ 
proaches mentioned previously. In fact, regulations can discourage companies from embracing innovation and 
breaking from prescribed operating methods. 

We need a regulatory system that is performance-based, one that allows businesses to set goals based on their 
distinctive set of issues and needs, while assuring the public can effectively monitor and influence that perfor¬ 
mance. One-size-fits-all regulation doesn’t match the rapid changes industry faces today. Instead, society must 
embrace a flexible system that asks businesses to be responsible for performance improvements and accountable 
for lapses in progress. Such a system requires trust and collaboration among all stakeholders: government, the 
environmental community, industry, and private citizens. 


79 


Chapter 2 - Guest Commentary 


Slowly, we are making progress on collaboration. Today, industry is often invited to the table as policies are 
debated and drafted. We’ve worked side by side on several occasions with colleagues from the EPA and Depart¬ 
ment of Energy on initiatives to test the concept of performance-based regulation. We’ve had some successes, 
and some failures, but ultimately, our success will depend on our collective and ongoing commitment to work 
together. 


80 


Chapter 2 - Guest Commentary 


Improving Both tHe Environment and 
Corporate Profits 

by 

Marc J. Epstein 

Price Waterhouse Visiting Professor-of-Accounting and Control 
INSEAD 

Fontainebleau, France 

Professor Epstein is also a member of the EPA's National Advisory Council on Environmental Policy and Technology 
(NACEPT). 

Industry has made great strides in reducing corporate environmental impacts from its products, processes, facili¬ 
ties, and other activities. Increasing numbers of companies have seen improvement in both the environment and 
their profitability from proactive environmental management rather than merely reacting to environmental regula¬ 
tions. Companies have discovered that techniques and technologies are available to improve environmental and 
corporate management and are beginning to use them. 

Many companies have been moving swiftly to integrate the consideration of environmental impacts into all as¬ 
pects of management decisions including product cost, product price, product and process design, capital invest¬ 
ments, and performance evaluations. But this is not yet widespread. Companies are often unsure about how 
evaluations of changing regulations, changing environmental technologies, and changing costs of those technolo¬ 
gies should be included in decisions. They also have difficulty evaluating the costs and benefits related to product 
life cycle impacts. Finally, even where techniques and technologies have been introduced in companies that both 
reduce environmental impacts and improve long-term corporate profitability, these techniques are often not spread 
among companies or even between the different business units or facilities of the same company. Sometimes this 
is blamed on decentralization and the inability of senior general managers or senior environment, health, and 
safety (EH&S) managers to motivate business unit and facility managers to institute environment protection and 
money-saving changes in products and processes. 

Nevertheless, the techniques and technologies are available that can improve corporate environmental perfor¬ 
mance and corporate profitability—win/win modifications. In many cases, financial analysis tools that are com¬ 
mon throughout industry are not being used in EH&S departments. In other cases, companies are being man¬ 
aged with a focus on regulatory compliance rather than environmental planning. 

Three of the areas of corporate improvement that have significant positive impacts for both the environment and 
corporate profits are capital investment decision making, cost management, and performance evaluation. 

Capital Investment Decision Making - Throughout industry, techniques such as scenario forecasting, Monte 
Carlo simulation, decision trees, and discounted cash flow analysis are commonly used for improving capital 
investment decisions. Most major companies would find it inconceivable that such decisions would be made 
without estimating the likely future cash flow and other impacts from the investment. Significant uncertainty 
related to projections of sales, competition, production costs, and many other factors often exists and long time 
horizons are not uncommon. Nevertheless, risk and uncertainty are appropriately factored into the decision 
analysis and the decisions are made. However, these techniques are typically not used in environmental equip¬ 
ment decisions and the evaluation of quality improvements that have benefits for both the environment and 



81 





Chapter 2 - Guest Commentary 


profits. Too often, companies view environmental improvements as driven by regulations and do not recognize the 
tremendous opportunities that are created by proactive environmental management. 

Companies that conduct product life cycle assessments on a regular basis find that numerous opportunities for 
improvement exist and provide changes in product and process design that not only reduce waste and increase 
production yield, but also increase product marketability and sales. Those companies that broadly identify their 
stakeholders and measure their life cycle impacts gain competitive advantage through improved product and pro¬ 
cess design and reduced environmental impacts. The life cycle assessment and life cycle costing process also 
provides the impetus for companies to bring together professionals from many parts of the company. This cross 
functional approach provides the setting for consideration of the impacts of the environment on accounting, 
finance, product and process design, legal, operations, marketing, etc. This is often the first time that many of 
these professionals have been brought into the consideration of the product design early enough to have an 
impact. Benefits are provided to the product, to the environment, and to corporate profits. 

Cost Management — It is well known in industry that “we manage what we measure”. Unfortunately, too many 
companies cannot identify their total environmental costs and thus do not recognize the significant impact that 
those costs have on their bottom line. They also don’t recognize that many of these costs can be controlled and 
reduced through strategic environmental management. Companies need to identify their environmental costs, 
track those costs, and then determine the causes of those costs through a system like activity based costing. The 
life cycle assessment and life cycle costing process also provides information that should be included in the full 
environmental cost accounting that is necessary to dramatically improve environmental management and reduce 
environmental costs. By identifying the causes of the costs, products and facilities can be identified that poten¬ 
tially make the most significant contributions to environmental cost reduction. Without this approach, the 
causes of environmental costs are often not clear and cannot be effectively managed. 

I have seen many companies that have dramatically underestimated their environmental costs because of inad¬ 
equate costing systems and did not recognize the significant opportunities for both cost savings and environmen¬ 
tal improvements that were available. Costs being understated by a factor of three or four is common and is 
caused by the tendency of accountants to place environmental costs in various overhead or general administra¬ 
tive expense accounts. This masking of the costs encourages the consideration of these costs as regulation- 
driven and does not encourage the consideration of the tremendous benefits of voluntary-driven, proactive, 
strategic environmental management. Full environmental costing is becoming even more critical as global 
industry recognizes the obligation for product take back and the ultimate responsibility for post consumer waste. 
Companies should be including these costs in capital investment, product-costing, and cost management deci¬ 
sions. 

Performance Evaluation — Through the integration of environmental impacts into capital investment and 
product costing decisions, managers are encouraged to consider the long term environmental and financial 
impacts of product and process decisions. But, if companies are to motivate proper decisions, they need to also 
recognize the incentives created by the performance evaluation system and make appropriate changes to encour¬ 
age managers to seek win/win improvements and make the proper tradeoffs when environmental improvements 
have no clear business advantage. Often capital investments are discouraged by performance evaluation metrics 
that cause a manager to forego profitable long-term investments for increasing current period income. Further¬ 
more, if companies want to make significant environmental improvements or change the corporate culture to 
encourage environmental sensitivity, an integration into the performance evaluation system is essential. Includ¬ 
ing an environmental performance metric into performance evaluations and bonus schemes can motivate changes 


82 


Chapter 2 - Guest Commentary 


that are congruent with company stated goals. Both lagging indicators of performance (measures of past environ¬ 
mental performance) and leading indicators (environmental management systems and improvements to reduce 
future environmental impacts) must be included in these evaluations of performance of divisions, teams, and 
managers. These measures will allow companies to evaluate and motivate performance, benchmark the company’s 
performance against its competitors, and strive for continuous improvement. 

Some companies still do not recognize the benefits from proactive strategic environmental management. In 
many cases they don’t recognize how existing measurement and management tools can be utilized to improve both 
the environment and profitability. The EPA could improve the environment and corporate profits through further 
development and promotion of the tools available for integrating environmental impacts into management deci¬ 
sions. 

Some companies see the measurement tools that can be used to improve costing and capital investment decisions 
as less reliable than traditional business and accounting measurement approaches. But, this is typically not the 
case. Increased usage of these tools in EH&S departments will improve environmental decision making, im¬ 
prove the environment, and improve corporate profitability. 

EPA’s involvement in promoting the use of these techniques and technologies and the encouragement of full 
environmental cost accounting and life cycle costing to improve corporate decision making will lead both corpo¬ 
rations and the EPA closer to their goals-the improvement of both environmental and financial performance. 


83 




Chapter 2 - Industry 





Chapter Three 

The Role of Other Federal 
Agencies in Prevention 


■ Federal Agency Pollution Prevention 
Activities 

- Department of Agriculture 

- U.S. Agency for International 
Development 

- Department of Commerce 

- Department of Defense 

- Department of Energy 

- General Services Administration 

- Department of the Interior 

- National Aeronautics and Space 
Administration 

- U.S. Postal Service 

- Department of Transportation 

- The White House 

■ Guest Comments: 

Fran McPoland, Federal Environmental 
Executive 

Sherri Goodman, Department of Defense 
Christine Ervin, Department of Energy 


85 



Chapter 3 - Other Federal Agencies 






M fj 



Chapter 3 - Other Federal Agencies 


Introduction 


With passage of the Pollution Prevention Act of 1990, pollution prevention became 
the national policy of the U.S. Government. The federal government is uniquely 
situated to promote and implement pollution prevention through its various roles: 

■ As policy maker and regulator, the government can exert influence through 
policies, education, regulations, and enforcement. 

■ As the nation’s single largest consumer and purchaser of goods and services, 
the federal government can help create markets for environmentally-preferable 
products and technologies. 

■ As a manager of facilities and generator of pollution, the federal government 
can set an example for excellence in pollution prevention and waste manage¬ 
ment. The federal government is the nation’s largest property owner and 
holds one-third of the nation’s land area. 

■ As an advocate for technology, the federal government can help accelerate the 
flow of pollution prevention technologies through policies and programs that 
support research and development and technology transfer. 

A number of government-wide actions have begun to put the national policy of pol¬ 
lution prevention into practice. An Assistant Secretary-level Interagency Task Force 
oversees implementation of the government’s long-term pollution prevention efforts. 
The environmental review process established in the Pollution Prevention Act and 
supported by the National Environmental Policy Act helps to ensure that adverse envi¬ 
ronmental impacts of proposed government activities are adequately considered in the 
decision-making process. 

Over the last six years, various federal agencies and departments have made signifi¬ 
cant strides in promoting a pollution prevention ethic internally and externally. The 
stimulus for much of this activity has been a series of laws and executive orders that 
have pushed federal agencies to adopt pollution prevention measures and guided their 
efforts as they did so. A summary of major milestones since 1990 is presented in Table 
3-1. EPA has also been encouraging federal agencies to find innovative ways to pre¬ 
vent pollution both in their own activities and in the multiple interactive effects their 
activities have on other segments of society. 

One of the most noteworthy landmarks in federal agency activity was Executive Or¬ 
der 12856, which requires federal agencies to report releases of toxic chemicals to 
EPA’s Toxics Release Inventory (TRI), to develop agency-wide and facility-specific 
pollution prevention plans, and to reduce toxic chemical releases by 50 percent by 
2001. Sixteen of the major federal agencies have developed pollution prevention 
strategies to achieve these and other pollution prevention goals. 

Federal facilities reported a 23.6 percent decrease in releases of toxic chemicals from 
1994 to 1995, according to TRI data. Whether that decrease is due to pollution pre- 


The federal 
government is 
uniquely situated 
to promote and 
implement 
pollution 
prevention 
through its 
various roles. 


87 



Chapter 3 - Other Federal Agencies 


vention measures or the fewer number of facilities reporting in 1995 (144 rather than 
193) is not yet clear. Table 3-2 summarizes the most recent TRI data for federal 
agencies. As the table shows, five federal agencies account for 99 percent of all 
federal agency reported releases — the Department of Defense (71 percent), U.S. 
Enrichment Corporation. (8.5 percent), Department of Energy (7 percent), National 
Aeronautics and Space Administration (6 percent), and the Department of Agriculture 
(6 percent). 

Several of the larger agencies achieved substantial reductions between 1994 and 1995. 
They include a 27 percent decrease for the Department of Defense, 8 percent for the 
Department of Energy, 14 percent for the National Aeronautics and Space Administra¬ 
tion, and 12 percent for the U.S. Enrichment Corporation. 

As strategies and policies are adopted and institutionalized, the emphasis is shifting 
to bringing pollution prevention to the facility level. EPA maintains a computerized 
Federal Facilities Tracking System with information on approximately 12,000 facili¬ 
ties of civilian federal agencies. (The total universe of federal facilities, including 


Figure 3-1. Total Number of Federal Facilities Per EPA Region 



Source: EPA. Federal Facilities Sector Notebook: A Profile of Federal Facilities. Washington, DC (EPA 300-B- 
96-003, January 1996). 


88 

















Chapter 3 - Other Federal Agencies 


those of the Department of Defense, is about 15,880.) Figure 3-1 shows the geo¬ 
graphic distribution of federal facilities by EPA Region. 

Over 5,000 federal facilities are currently in the process of preparing field-level plans 
in response to Executive Order 12856 and other requirements. Many federal facilities 
have environmental management systems in place or are considering adoption of the 
ISO 14001 Environmental Management Standard. As another alternative, EPA re¬ 
cently issued a Code of Environmental Management Principles, developed in consul¬ 
tation with other federal agencies under Executive Order 12856. Individual facilities 
and agencies are encouraged to adopt the Code, which embodies five principles: man¬ 
agement commitment, compliance assurance and pollution prevention, necessary en¬ 
abling systems, performance and accountability, and measurement and improvement. 

This chapter presents a sample of the activities of federal agencies that have been 
particularly active in pollution prevention. Federal agency pollution prevention ac¬ 
tivities include program and facility management, research and development, tech¬ 
nological innovation, information transfer, partnership programs, and acquisition. 








Chapter 3 - Other Federal Agencies 


Table 3-1. Pollution Prevention Milestones 

Pollution Prevention Description 

Milestone 


September 1990 - Science 
Advisory Board report calls 
for pollution prevention 

In this influential report, Reducing Risk: Setting Priorities and Strategies fc 
Environmental Protection, EPA’s Science Advisory Board stated as a major 
recommendation that “EPA should emphasize pollution prevention as the 
preferred option for reducing risk.” The report further points out that “some 
pollution prevention techniques...can pay for themselves quite apart from 
environmental considerations.” 

November 1990 - Pollution 

Act of 1990 

Congress affirmed its commitment to a new approach for improving Preventioi 
environmental quality by passing this legislation. Congress recognized the 
important leadership role that federal agencies must play in the pollution 
prevention arena. In the Act, Congress directed EPA to: (1) promote source 
reduction practices in other federal agencies and, (2) identify opportunities 
to use federal procurement to encourage source reduction. 

January 1991 - EPA issues 
National Pollution Prevention 
Strategy 

The National Pollution Prevention Strategy (FR 56:7849-64, February 26, 
1991) outlines EPA’s pollution prevention policy. EPA’s National Strategy 
also commits the Agency to develop similar strategies for other sectors of the 
economy, including agriculture, energy and transportation, and the federal 
government. 

April 1991 - Executive 

Order 12759 (Federal 

Energy Management) 

This order directs all federal agencies, among other things, to reduce their 
energy use and increase energy efficiency in federal buildings and facilities 
by at least 20 percent from 1985 levels by the year 2000. 

October 1991 - Executive 

Order 12780 (Federal 

Recycling and Procurement 
Policy) 

This order was designed to promote a greater role in waste reduction and 
recycling on the part of all federal agencies and to set up a special council 
that will monitor and report on agency performance. Under the EO, each 
federal agency must initiate a waste reduction and recycling program, and 
must designate an Agency Recycling Coordinator responsible for coordinating 
agency activities on waste reduction and recycling and for reporting the 
information to EPA. The order also establishes a Council on Federal 

Recycling and Procurement Policy to encourage active participation in 
waste reduction, recycling, and procurement programs, recommend changes 
in federal agency specifications and standards to enhance acquisition of 
recycled products, and showcase effective programs being developed. 


90 


Chapter 3 - Other Federal Agencies 


Table 3-1. Pollution Prevention Milestones (Cont'd) 

Pollution Prevention Description 

Milestone 


April 1992 - EPA and the 

U.S. Department of Agriculture 
(USDA) signed a Memorandum 
of Agreement to implement 
increased pollution prevention 

The Memorandum of Agreement (MOA) puts in place a plan to 
address agriculturally related environmental problems and to implement 
increased pollution prevention in the agricultural sector. The Agreement 
outlines four basic strategies to achieve environmental results: 

(1) implementation of a nationwide pollution prevention program to minimize 
agriculturally-related pollution and environmental risks; (2) establishment of a 
coordinated research, technology development, and technology transfer system 
that supports production practices that protect and enhance the environment; 

(3) implementation of a comprehensive marketing strategy to promote 
voluntary pollution prevention; and (4) strengthening of the working 
relationship between EPA and USDA in order to provide a unified force for 
positive change in the area of agricultural pollution prevention. 

September 1992 - Policy 

Directive issued by the 

Secretary of Energy 

The Directive commits DOE to participate in the 33/50 Program and initiate 
full voluntary Toxics Release Inventory (TRI) reporting for all DOE facilities. 
DOE agreed to strive to achieve, by the end of 1995, a 50 percent reduction in 
releases of 17 priority chemicals from facilities that are currently required to 
submit TRI reports; all other DOE facilities would initiate voluntary TRI 
reporting beginning in 1993, with a 33 percent reduction goal for the 17 
chemicals by the end of 1997. DOE also agreed to initiate a review of its 
specifications and standards, beginning with reductions in the use of the 17 
priority chemicals in the 33/50 Program. 

October 1992 - Energy 

Policy Act of 1992 

The law gives a major boost to energy efficiency and renewable energy. It 
includes provisions on alternative fuels, electricity, global warming research, 
and more. To encourage energy efficiency, the law uses a mixture of voluntary 
and mandatory measures, requiring new efficiency standards for appliances that 
use energy and water. The law promotes the use of alternative fuels, requiring 
certain federal, state and private fleets of cars to increase their number of 
alternative-fueled vehicles. Tax credits and federal loan support are provided 
for renewable energy projects; a variety of research programs are authorized as 
well. The Act also gives whole-sale power producers greater, more affordable 
access to transmission lines and transmission services. 

April 1993 - Executive Order 
12843 (Procurement 
Requirements and Policies 
for Federal Agencies for 
Ozone-Depleting Substances) 

Federal agencies are directed by this order to purchase products that contain 
non-ozone depleting components to the extent economically feasible. Through 
affirmative procurement the U.S. government will provide the leadership to 
phase out ozone depleting products on a worldwide basis. 


91 









Chapter 3 - Other Federal Agencies 

Table 3-1. Pollution Prevention Milestones (Cont'd) 

Pollution Prevention Description 

Milestone 


April 1993 - Executive Order 
(Federal Use of 

Alternative as Fueled Vehicles) 

Under this order, federal agencies are directed to aggressively procure 12844 
alternative fueled vehicles in order to stimulate the market for such products 
well as push the state of technology. 

April 1993 - Executive Order 
12845 (Purchasing Energy 
Efficient Computer 

Equipment) 

This order directs federal agencies to procure computers, monitors and printers 
that meet EPA’s Energy Star energy specifications. Equipment meeting specific 
energy reduction criteria bears an Energy Star label. 

August 1993 - Executive Order 
12856 (Federal Compliance 
with Right-to-Know Laws and 
Pollution Prevention 
Requirements) 

This order requires federal agencies to comply with the following: 1) develop 
a facility-wide pollution prevention plan by December 31, 1995, including a 50 
percent reduction in toxic chemicals by 2001; 2) ensure that pollution 
prevention plans support agency-wide reduction strategies and goals; 3) 
establish agency plans and goals to eliminate or reduce acquisition of 
products containing hazardous substances or toxic chemicals; 4) make all 
pollution prevention strategies, plans, and TRI reports available to 
surrounding communities; 5) comply with EPCRA emergency planning and 
response requirements; and 6) report releases and transfers of toxic chemicals 
to the TRI. 

These federal agency pollution prevention plans will direct implementation of 
EO 12856 at more than 2,400 covered facilities throughout the country. 

October 1993 - Executive Order 
12873 (Federal Acquisition, 
Recycling and Waste 

Prevention) 

This order directs federal agencies to set goals for solid waste prevention and 
recycling to be achieved by 1995 and to implement affirmative acquisition 
programs for all designated EPA guideline items purchased (replaced EO 
12780). EPA must issue guidance on environmentally preferable products and 
expedite the process of designating products with recycled content. The EO 
establishes high-level environmental executive positions and staffing to 
ensure implementation of the directives, establishes model facility and 
recycling programs, and sets minimum recycled content standards for 
printing and writing paper. Federal agencies that meet the objectives of this 
order are recognized with the White House Closing the Circle Award 
(discussed in the next table). 

March 1994 - Executive Order 

12902 (Energy Efficiency and 
Water Conservation at Federal 
Facilities) 

This order requires agencies to set goals of reducing energy consumption, 
increasing energy efficiency, auditing their facilities for energy and water use, 
purchasing energy-efficient products, increasing the use of solar and other 
renewable energy sources, designating a “showcase” facility, and minimizing 
use of petroleum-based fuel. 


92 


Chapter 3 - Other Federal Agencies 

Table 3-1. Pollution Prevention Milestones (Cont'd) 

Pollution Prevention Description 

Milestone 

August 1995 - Executive Order This order directs federal agencies to procure products with companies that 

12969 (Federal Acquisition and are in compliance with TRI reporting requirements. 

Community Right to Know) 


93 








Chapter 3 - Other Federal Agencies 


Table 3-2. TRI Data for Federal Facilities 

Federal Agency 

Total 1995 Releases 
(millions of pounds) 

Percent Change in Chemicals 
Reported in 1994/1995 

Department of Agriculture 

474.9 

- 

Department of Defense 

5,615.3 

-26.7 

Air Force 

3,651.8 

-25.5 

Army 

917.6 

-29.1 

Army Corps of Engineers 

22.4 

0.2 

Defense Logistics Agency 

5.3 

-83.1 

Marines 

375.0 

-26.5 

Navy 

643.1 

-28.9 

Department of Energy 

581.9 

-7.7 

Department of Health and Human Services 

0 

-100.0 

Department of Interior 

4.8 

316.5 

Department of Justice 

32.5 

-64.8 

Department of Transportation 

16.5 

-30.7 

Department of Treasury 

37.6 

493.3 

Department of Veterans Affairs 

0 

- 

Environmental Protection Agency 

0 

-45.0 

National Aeronautics and Space Administration 

474.0 

-13.7 

Tennessee Valley Authority 

13.6 

-100.0 

U.S. Enrichment Corporation 

675.7 

-11.7 

Total 

7,927.0 

-23.6 


Source: EPA. 1995 Toxics Release Inventory: Public Data Release (EPA 745-R-97-005, April 1997). Tables 4- 
16 and 5-7. 


Under Executive Order 12873, federal agencies are recognized for their 
achievement in meeting the objectives of this order; for this purpose, the White 
House Closing the Circle Award was established. The categories of this award are 
described in Table 3-3. 


94 



Chapter 3 - Other Federal Agencies 

Table 3-3. Closing the Circle Awards 1 


Award Category 

Description 

Waste Prevention 

This award is given to nominees who have made significant reductions in: 

• the generation of non-hazardous, solid wastes from a federal facility 
through any changes in the design, manufacturing, or use of materials or 

products; or 

• the amount of toxicity in waste materials before becoming municipal solid 
waste. 

Recycling 

products 

This award is given for collection, separation and processing by which 
or other materials are recovered from the solid waste stream for use in the 
manufacture of new products (other than fuel for producing heat or power by 
combustion). 

Affirmative Procurement 

This award recognizes the most effective programs implemented to purchase 
and use products containing recovered materials at a federal site, facility, or 
operation. The award focuses on those products designated by the EPA 
Comprehensive Procurement Guidelines (CPG), covering 24 different items. 

Environmental Innovation 

This award recognizes the best examples of: 

• acquiring, using or validating products or services that have a lesser or 
reduced effect on human health and the environment when compared with 
competing products or services that serve the same purpose; 

• outstanding improvements to a process that result in significant monetary 
savings and benefit the environment; and, 

• product testing that leads to the approval and use of environmentally sound 
products and services. 

Model Facility 

Demonstration 

This award is given to federal facilities that have made outstanding 
contributions to waste prevention, recycling and affirmative procurement 
through leadership, investment in resources, and change in culture. 

Sowing the Seeds of Change 

This award is given to programs that do not fall under one of the previous five 
categories. The Closing the Circle Award Program does not limit consideration 
for award recognition to strict parameters; its objective is to recognize all 
applicable environmental innovations and successes. 


1 Nomination forms for Closing the Circle Awards are available from the Office of the Federal Environmental Executive (OFEE) (202-260- 
1297). Recent winners of these awards are profiled in Closing the Circle News, also available from the OFEE. 


95 






3 - Other Federal Agencies 


Federal Agency Pollution Prevention 
Activities 

Department of Agriculture 

The U.S. Department of Agriculture (USDA) contributes to pollution prevention through 
a number of programs. Many of these programs have emphasized reducing pollution 
from excessive agricultural chemicals or soil nutrient management and soil conserva¬ 
tion issues. Programs dealing with pesticide reduction and environmentally sound use 
are found in several USDA agencies, including the Cooperative State Research, Edu¬ 
cation, and Extension Service, which maintains several grant programs in research and 
extension in this area, the Agricultural Research Service, the Forest Service, the Natu¬ 
ral Resource Conservation Service, and the Animal and Plant Health Inspection Ser¬ 
vice. 

One major pollution prevention program is the $ 12 million a year Sustainable Agricul¬ 
ture Research and Education (SARE) program, in which EPA also participates. This 
program provides competitive grants for research, education, and extension projects 
through four regions of the country. These projects help farmers reduce pesticide use 
and manage fertilizers and animal wastes more efficiently and with less environmental 
impact. The projects also assist farmers reduce other input use that could contribute to 
water and air pollution, such as energy use. The program relies heavily on farmer 
involvement and is particularly supportive of projects taking a systems approach to 
agricultural and environmental problems. EPA participates in all facets of the SARE 
program, particularly the joint USDA-EPA program. Agriculture in Concert with the 
Environment (ACE). The ACE program provides grants aimed at pollution preven¬ 
tion and other environmentally-related agricultural issues. 

U.S. Agency for International Development 

The U.S. Agency for International Development’s (U.S. AID) Environmental Pollu¬ 
tion Prevention Project (EP3) program is a global initiative focused on creating and 
supporting locally sustainable pollution prevention programs to address industrial 
and urban waste problems in developing countries. 2 EP3 provides technical assistance 
to help participating countries understand how pollution prevention can be used to 
address environmental problems. This assistance falls into four general categories: 
diagnostic assessments and other technical assistance; training; information dissemi¬ 
nation; and assistance in developing sustainable government and non-governmental 
pollution prevention programs. 

EP3 has established pollution prevention offices in Santiago, Chile, and Tunis, Tuni¬ 
sia. Two additional offices are being established in Egypt and Ecuador. The program 
also has a Headquarters (HQ) Clearinghouse that serves as a repository and distribu- 


2 U.S. EPA, Envirosense EP3 Program Summary. 



Chapter 3 - Other Federal Agencies 


tion point for pollution prevention information. The HQ Clearinghouse contains ap¬ 
proximately 1,000 items compiled into the EP3INFO data base. The HQ Clearing¬ 
house, through its linkage with INFOTERRA/USA, has access to several hundred data 
bases, EPA documents, and other information sources. This linkage allows the HQ 
Clearinghouse to offer users worldwide access to a wide range of pollution prevention 
resources. The EP3INFO data base also has been distributed to local clearinghouses 
in Chile and Tunisia. Similar clearinghouses will be established as new program of¬ 
fices are opened in additional countries. 

As an example of EP3 activities abroad, EP3’s program in Chile has an independent 
Pollution Prevention Center. The steering committee consists of the American-Chil- 
ean Chamber of Commerce (AMCHAM), USAID/Chile, and EP3. EP3’s office in 
Chile is headed by a Chilean engineer, and a group of 16 in-country consultants are 
providing pollution prevention consulting services beyond EP3 project support. The 
program has trained Chilean nationals in pollution prevention, and established a 
clearinghouse with the Centro de Investigacion y Planificacion del Medio Ambiente 
(CIPMA) in August 1994. CIPMA is an environmental information center that pro¬ 
vides information to industry and academia through its main office in Santiago and 
eight regional network nodes throughout the country. 

EP3’s office in Chile has also conducted assessments for a wide range of indus¬ 
tries such as textiles, leather tanning, printing, paint processing, metal finishing, 
and processing. 

Department of Commerce 

Congress established the U.S. Department of Commerce Technology Administration’s 
National Institute of Standards and Technology (NIST) “...to assist industry in the 
development of technology...needed to improve product quality, to modernize manu¬ 
facturing processes, to ensure product reliability...and to facilitate rapid 
commercialization...of products based on new scientific discoveries.” The primary 
mission of NIST is to promote U.S. economic growth by working with industry to 
develop and apply technology, measurements, and standards. 3 This mission is carried 
out through four major programs: 

■ A competitive Advanced Technology Program that provides cost-shared grants 
to industry for the development of high-risk technologies with significant 
commercial potential (including pollution prevention technologies); 

■ A grassroots Manufacturing Extension Partnership that helps small and me¬ 
dium-sized companies adopt new technologies (including pollution prevention 
technologies); 

■ A laboratory effort planned and implemented in cooperation with industry that 
focuses on measurements, standards, evaluated data, and test methods; and 


3 U.S. Department of Commerce, Technology Administration. Guide to NIST - National Institute of 
Standards and Technology. 


97 




Chapter 3 - Other Federal Agencies 


■ An outreach program associated with the Malcolm Baldridge National Quality 
Award. 


MEPs Infonnation/Technology Assistance 

The Manufacturing Extension Partnership (MEP) is a true partnership of federal and 
state organizations working together to address the needs of small and medium-sized 
manufacturers. At the heart of the MEP system is a network of regional manufacturing 
extension centers in all 50 states and Puerto Rico. MEP works with state and local 
organizations to either establish a new program or expand existing services for smaller 
manufacturers. Located throughout the country, these centers are created through a match 
of federal, state, and local funding. They are not federal offices, but instead are not-for- 

profit organizations. 

Centers provide direct ser¬ 
vices to smaller manufactur¬ 
ers, helping them address 
their most critical needs in areas such as production techniques, technology applica¬ 
tions, and business practices. 


Preliminary Census surveys of MEP clients indicate that the national system is 
projected to create or save over 30,000 jobs annually and help companies achieve 
sales $550 million higher than if they had not received MEP services. 


The MEP Environmental Program works to strengthen the environmental competi¬ 
tiveness of small manufacturers. The Program works with MEP centers and affiliated 
organizations to integrate environmental services into the manufacturing extension 
services of the MEP system. The Environmental Program manages and funds the 
development of environmental tools and supports the training of MEP field agents and 
their local partners in providing environmental and manufacturing technical assistance 
to small and medium-sized manufacturers. 


MEP now has affiliate centers in all 50 states and Puerto Rico. 


Department of Defense 4 

The Environmental Quality Program is an integral part of the overall mission of the 
Department of Defense (DoD). Environmental considerations permeate all aspects of 
the development and operation of an installation and the development, testing, pro¬ 
curement, deployment, and final disposal of a weapon system. DoD’s Environmental 
Quality Program protects DoD personnel and surrounding communities from expo¬ 
sure to hazardous materials and reduces pollution to the air, land, and water. 

The Secretary of Defense has identified three priorities for DoD, each of which is 
clearly linked to the Environmental Quality Program: 

■ Readiness - DoD must be able to test its weapon systems and train personnel so 
that it has the ability to accomplish its mission. 

■ Quality of Life - DoD must provide its personnel, both military and civilian, 
with a healthy environment in which to live and work. 


98 


4 This information has been extracted from DoD's Defense Environmental Quality Program, Annual 
Report to Congress for Fiscal Year 1995. For a copy of this report, contact Jim Kennedy at (703) 604- 
1766. 



Chapter 3 - Other Federal Agencies 


■ Modernization - DoD must provide its personnel with state-of-the-art equip¬ 
ment and facilities superior to that of any potential adversary. 

DoD’s Environmental Quality Program directly supports these objectives by manag¬ 
ing the 25 million acres on which DoD conducts activities to provide realistic training 
opportunities; managing the flow of hazardous materials and wastes to ensure a safe 
environment for personnel; and introducing new materials and maintenance processes 
for weapon systems that reduce costs and improve performance. 

In the following sections, DoD’s efforts in pollution prevention, conservation, educa¬ 
tion and training, and environmental technology are discussed. 


Pollution Prevention 

DoD is focusing on source 
reduction, reuse, and recy¬ 
cling in lieu of “end-of- 
pipe” treatment and dis¬ 
posal as its preferred 
method of protecting hu¬ 
man health and the envi¬ 
ronment and meeting cur¬ 
rent legal requirements. 

This preventive approach 
reduces future environ¬ 
mental and legal risks and 
Operations and Manage¬ 
ment (O&M) costs. 

During FY95, DoD in¬ 
vested over $284 million in 
pollution prevention. The 
O&M accounts provided 
55 percent of this invest¬ 
ment. The procurement 
account was another major 
contributor (28 percent). 

Figure 3-2 shows the dis¬ 
tribution of pollution pre¬ 
vention funds. Approxi¬ 
mately 32 percent of the 
funds were used to reduce 

the use of ozone depleting substances (ODS), 31 percent to reduce the use of hazard¬ 
ous materials and generation of hazardous waste, 25 percent to reduce solid waste 
disposal and support recycling activities, 6 percent to reduce water pollution, and 6 
percent to reduce air pollution. 


The DoD Environmental Quality Program 

DoD’s Environmental Quality Program is divided into the following major functions: 

Planning is the foundation of the Environmental Quality Program. DoD’s planning 
efforts focus on the development and operation of installations and the development, 
procurement, deployment, and disposal of weapon systems. 

Compliance includes all activities required to meet the standards established by 
laws such as the Clean Air Act (CAA), the Clean Water Act (CWA), and the 
Resource Conservation and Recovery Act (RCRA). These laws are designed to 
protect human health and the environment. Failure to comply with environmental 
laws can place personnel at risk; make surrounding air, land, and waters unsafe; 
and result in penalties, shutdowns, or restrictions on mission activities. 

Pollution Prevention protects human health and the environment by reducing or 
eliminating pollution problems rather than controlling them. Pollution prevention 
can be used as a means of achieving compliance and usually involves, good business 
decisions that reduce overall costs. 

Conservation involves the maintenance and protection of both natural and cultural 
resources that have been entrusted to DoD’s care. A healthy natural environment 
contributes to realistic training as well as quality of life. Protection of cultural 
resources preserves the nation’s heritage. 

Education and Training ensures that DoD personnel understand the environmental 
responsibilities of their jobs and therefore support the achievement of DoD’s overall 
Environmental Quality Program. 

Environmental Technology seeks new technologies that meet environmental 
requirements at less cost. 


99 






Chapter 3 - Other Federal Agencies 


Figure 3-2. DoD Pollution Prevention Funding for FY95 (by Media) 


Air Emission 
Reduction 

c 


Other* 

25% 



Water Pollution 
Reduction 
6 % 



* Other includes nonpoint source pollution reduction, toxic release reductions, solid 
waste reduction, and “other.” 

DoD has encouraged installations to seek smarter ways of doing business and to re¬ 
duce environmental costs through the establishment of goals. One goal is to reduce 
the amount of hazardous waste disposed 50 percent by 1999 from a 1992 baseline. As 
the first step in achieving this goal, installations were required to complete opportunity 
assessments and develop pollution prevention plans by the end of 1995. The assess¬ 
ments identified the users of hazardous materials and the generators of hazardous wastes. 
The plans identified alternative materials and processes and prioritized them based 
upon return on investment and environmental performance. 

A large reduction in the purchase of hazardous materials and the disposal of hazard¬ 
ous wastes can be attributed to improved business practices. DoD components are 
establishing centralized systems, known as pharmacies, for buying, storing, distrib¬ 
uting, and disposing of hazardous materials at many installations and on most ships. 
Materials are distributed to industrial shops on a “just-in-time” basis and in quanti¬ 
ties sufficient only for the immediate task. This practice reduces: the amount of 
hazardous materials purchased, losses due to shelf-life expiration, the number of 
accumulation points (and the potential for violations), and the amount of hazardous 
waste disposed. The Navy is implementing this program at 73 shore facilities and on 
140 ships and estimates a cost avoidance of more than $20 million for FY95. Simi¬ 
lar successes are reported by the Army and Air Force. 

DoD also is implementing a program to dramatically reduce its releases of toxic chemi¬ 
cals under Executive Order 12856. For 1994, the first year that requirements to report 
releases of toxic chemicals applied to DoD, 131 of 425 major DoD installations had 
toxic releases that exceeded the threshold levels. The 1994 baseline, by which progress 
is to be measured in future years, included both on-site releases to air, land, and water 
as well as off-site transfers of waste for treatment, storage, or disposal. The total 


100 



Chapter 3 - Other Federal Agencies 


amount released during the baseline year was 11.46 million pounds. About two-thirds 
of this total was released on-site primarily as air emissions. The remaining one-third 
was waste transferred off-site. The total of all DoD reported releases was less than 
one-half of one percent of the total releases from private industry reported in 1993 
(most current data available). 

In the past five years, DoD has conducted an aggressive program to eliminate the use 
of ozone-depleting substances (ODSs). This effort was motivated by the production 
phaseout of ODSs by the end of 1995 in accordance with the international Montreal 
Protocol Treaty. The Department must identify and validate alternative materials 
before changes can be made. Typical investments included the purchase of aqueous 
washers to replace cleaning systems that used solvents containing ODSs. DoD re¬ 
duced its procurement of ODS-based solvents and refrigerants from 14.6 million pounds 
in 1990 to 313,000 pounds in 1995 — a 98 percent reduction. 

DoD has not found suitable substitutes for all materials and all applications. For ex¬ 
ample, no material has been found that will equal the performance of halon as a fire 
suppressant for jet aircraft engines. As a consequence, while research continues to 
seek an alternative, DoD must continue to use halon in its aircraft. Nevertheless, 
overall use of halon has been dramatically reduced, dropping from 10.3 million pounds 
in 1990 to 231,000 pounds in 1995 — a 97 percent reduction. 

To reduce landfill disposal costs and potential environmental risks, DoD established 
goals to reduce the generation of nonhazardous waste and to increase recycling ac¬ 
tivities. The goals required a 50 percent reduction in the amount of nonhazardous 
waste shipped to landfills by 1999 from a 1992 baseline, and a 50 percent increase in 
the amount of waste recycled by 1999 from a 1992 baseline. Significant progress 
already has been made towards achieving these goals. For example, Naval Air Station 
Whidbey Island, Washington, when faced with the imminent closure of its landfill, 
implemented aggressive recycling and composting programs. In FY95, revenues from 
recycling exceeded $285,000. In the same period, cost avoidances through reductions 
in nonhazardous waste disposal totaled more than $784,000. Overall, DoD reduced 
nonhazardous waste disposal 20 percent and increased recycling 45 percent. 

During FY95, DoD also developed new policies and procedures to substantially change 
the way in which weapon systems are developed and procured. The new policies 
required that environmental life-cycle costs be understood fully in the early stages of 
the acquisition process. This policy has encouraged developers of new weapon sys¬ 
tems to seek alternative materials and processes that reduce future operations, mainte¬ 
nance, and disposal costs. 

In FY97, DoD will continue to invest in projects to decrease its use of hazardous 
materials and its generation of pollutants. There will, however, be fewer investments 
related to ODSs since most uses already have been phased out. In FY97, DoD is 
launching two new initiatives that have the potential to significantly reduce future 
environmental costs. The first initiative, entitled ENVVEST, is intended to promote 
more effective use of environmental investments. Installation commanders will iden- 


101 




Chapter 3 - Other Federal Agencies 


ENVVEST at Vandenberg AFB 

In July 1996, a pilot ENVVEST project was launched at Vandenberg Air Force 
Base in California. Vandenberg was the first DoD installation to sign up for relief 
from selected EPA regulations, and plans to redirect environmental compliance 
funds into water conservation, air, and water pollution prevention projects. Among 
Vandenberg’s proposals are a reduction in NOx emissions by a minimum of 10 
tons during the five-year life of the pilot project, closed-loop recycling for waste- 
water, and on-site batch treatment plants at three major space launch complexes. 
DoD will conduct an independent evaluation of the progress of the program. At 
the kick-off event, DoD Under Secretary Sherri Goodman noted, “ENVVEST opens 
the door to creative solutions for local problems. In twenty years, we will look 
back at this event and wonder why we didn’t do this sooner.” 


tify regulations that require 
large investments but pro¬ 
duce little or no environmen¬ 
tal improvement. Regula¬ 
tors, now allowed to relax en¬ 
forcement of rules under spe¬ 
cific circumstances, would 
enter into agreements with 
the commanders. These 
agreements would specify 
the regulations that would be 
relaxed and an alternative en¬ 
vironmental approach that 


would be pursued. DoD an¬ 
ticipates that most of the alternative efforts would be high payback pollution preven¬ 
tion projects. The Department believes by using the flexibility permitted under this 
initiative, the installation could achieve greater overall environmental protection and 
reduce costs. The initiative will be tested at three to five installations. 


The second initiative involves the use of data from the TRI to better focus pollution 
prevention and environmental technology efforts. The DoD components operate many 
weapon systems that were developed before there was full understanding of the liabili¬ 
ties and costs associated with the handling of hazardous materials and disposal of 
hazardous waste. Many specifications, cited by operations and maintenance manuals 
for these older systems, direct the use of hazardous materials. DoD intends to change 
these specifications to prescribe more environmentally benign substitutes. However, 
there are thousands of specifications to be reviewed and potentially changed. DoD 
must focus its efforts on those specifications that create the largest part of the problem. 
DoD proposes to analyze the TRI data to identify those processes and associated weapon 
systems that require priority attention. 

Conservation 


In FY95, DoD invested $152 million to support conservation activities. In order to 
meet its legal obligations and to properly operate and maintain operational ranges and 
maneuver areas, DoD established goals to complete inventories of special resources, 
such as threatened and endangered species habitat, and to prepare integrated manage¬ 
ment plans for both natural and cultural resources. The goals required that most inven¬ 
tories be completed by FY98 and all plans be completed by FY01. 

DoD made significant progress towards achieving these goals. At the end of FY95, 
over 66 percent of the biological inventories and 68 percent of the wetlands invento¬ 
ries were completed. In addition, nearly 50 percent of the historic building inventories 
and 34 percent of the archaeological inventories were completed. 

DoD also made substantial progress in the preparation of integrated management plans. 
Over 51 percent of the integrated natural resource plans and 36 percent of the inte¬ 
grated cultural resource plans have been completed. 


102 


Chapter 3 - Other Federal Agencies 


In order to improve mission performance, DoD has made small investments in the 
study, protection, and enhancement of some natural resources. For example, it has 
studied the migratory patterns and nesting preferences of birds. This information 
has enabled flight planners to adjust low level aircraft training routes to reduce the 
potential of birdstrikes and the resulting loss of aircrews and aircraft. This infor¬ 
mation also assisted land managers in selecting maintenance practices that dis¬ 
courage birds from nesting near airports. In some instances, DoD has taken ac¬ 
tions to promote plant and animal species, particularly those identified as threat¬ 
ened or endangered. These actions have led to increased operational flexibility on 
some installations. 

DoD is convinced that natural resources should be managed as part of an entire eco¬ 
system. This approach is being used in the Mojave Desert, where some of the most 
important training and testing installations are located. DoD, in coordination with 
other major landowners in the desert ecosystem, is collecting existing data on natural 
and cultural resources to develop a desert-wide land management plan. DoD antici¬ 
pates that the resulting plan will give installation commanders more flexibility, protect 
installations from encroachment and restrictions on military operations, protect criti¬ 
cal species, and support orderly economic development. 

The Army is implementing new land management practices at its training ranges. 
Army exercises, when conducted without safeguards, can cause extensive damage 
to vegetation and terrain and undermine the effectiveness of future training activi¬ 
ties. A comprehensive training land use management approach, called Integrated 
Training Area Management (ITAM), attempts to balance training needs with the 
ability of soils and vegetation to absorb and recover from training uses. 

In FY97, DoD will continue to complete inventories and develop integrated man¬ 
agement plans. In addition, in compliance with the Native American Graves Pro¬ 
tection and Repatriation Act, DoD will continue efforts to identify human remains 
and associated funerary objects of Native American origin that have been uncov¬ 
ered on DoD lands and attempt to return them to appropriate representatives of 
Native American tribes for reburial. 

Education and Training 

DoD intends to educate or train all personnel, both military and civilian, to meet 
the environmental responsibilities associated with their jobs. 

In FY95, DoD completed an inventory of all environmental education require¬ 
ments and began to identify the most cost-effective means of satisfying them. When 
practical, DoD has embedded environmental education into existing courses. En¬ 
vironmental education has been incorporated into basic training and technical spe¬ 
cialty training curricula. Environmental education also has been added to profes¬ 
sional military education programs such as Army War College and Air Command 
and Staff College. DoD began to incorporate environmental education into courses 
offered by the Defense Acquisition University. 


103 


Chapter 3 - Other Federal Agencies 


In FY97, DoD will prepare an environmental career development program. This pro¬ 
gram will aid the development of environmental personnel for positions of greater 
responsibility. For the first time, environmental professionals will have a clear vision 
of the environmental career ladder. 

Environmental Technology 

DoD is seeking innovative technologies to meet environmental performance standards 
in an effective, cost-efficient manner. 

DoD’s overall strategy for environmental technology is to identify and establish pri¬ 
orities among users’ needs and match them if possible to existing technologies. If 
existing technologies are not available, then the development of new technologies is 
pursued through the environmental technology program. 

In FY95, DoD invested over $ 164 million in environmental technology. Of this amount, 
approximately $108 million was invested in direct support of the Environmental Qual¬ 
ity Program. Over $54 million was allocated for pollution prevention, $45 million for 
compliance, and over $9 million for conservation. 

In FY95, the Air Force was designated executive agent for preparing the DoD Envi¬ 
ronmental Technology Requirements Strategy (DETRS). The first DETRS was pub¬ 
lished in March 1995. This document contained technology goals and requirements 
identified and prioritized by the users. It established the direction for future technol¬ 
ogy investments. 

The Environmental Security Technology Certification Program (ESTCP) also was 
launched in FY95. This program also was established to demonstrate and validate 
the most promising new technologies to meet urgent DoD needs. Successful candidate 
projects were expected to achieve payback within five years. 

There were a number of new technologies successfully implemented in FY95. The 
Navy successfully developed and fielded the plastic waste processing system to com¬ 
ply with the Marine Plastic Pollution Research and Control Act of 1987, as amended 
by the Defense Authorization Act of 1994. The Air Force implemented the aircraft 
component subsystem paint stripper. This is expected to reduce the amount of haz¬ 
ardous waste generated during stripping operations by 94 percent and the labor hours 
required to strip an aircraft by 50 percent. 

In FY97, DoD will continue to invest in environmental technology projects. The ef¬ 
fort will focus on problems that are unique to the military or offer significant reduc¬ 
tions in current operations and maintenance costs. Examples include the develop¬ 
ment of an antifouling coating for ships and the development of an ultraviolet oxida¬ 
tion process to treat air systems contaminated with nitroglycerin and solvents. 


104 


Chapter 3 - Other Federal Agencies 


Department of Energy 

Program Management 

In December 1995, the Department of Energy (DOE) was honored along with 20 pri¬ 
vate sector companies with an “Environmental Champion” award. The award, co¬ 
sponsored by EPA and McGraw-Hill Company’s Chemical Engineering and Environ¬ 
mental Engineering World Magazines, was presented to DOE for its success in EPA’s 
33/50 Program. DOE, the 
only federal agency receiving 
an award, reduced its use of 
17 targeted chemicals by 95 
percent between 1988 and 
1993. 

DOE has renewed its efforts 
to prevent wastes wherever 
possible as a way to reduce 
costs. In her May 3, 1996 
memorandum and accompa¬ 
nying 1996 Pollution Preven¬ 
tion Program Plan, Secretary of Energy Hazel O'Leary demonstrated the Department’s 
commitment to pollution prevention by establishing DOE’s most ambitious waste re¬ 
duction, recycling, and affirmative procurement goals to date. These goals, to be 
achieved by the end of 1999, were developed in accordance with recent Executive 
Orders and internal departmental guidance. DOE field sites are required to set spe¬ 
cific goals to help achieve the overall departmental goals. 

In December 1995, DOE’s Office of Environmental Management released the Annual 
Report on Waste Generation and Waste Minimization Progress for calendar year 1993. 
This report showed two trends: (1) environmental restoration and facility stabilization 
activities are the primary waste generating activities; and (2) DOE continues to re¬ 
duce, recycle, reuse, and avoid waste generation wherever possible. The report also 
concluded that between 1991 and 1993 routine operations waste generation decreased 
35 percent, while sanitary waste generation increased by approximately 26 percent. 

DOE has institutionalized pollution prevention in several important ways: 

■ Establishing a top-level Pollution Prevention Executive Board, chaired by the 
Under Secretary, to set priorities and assist in achievement of goals; 

■ Creating an Office of Pollution Prevention within the Office of Environmental 
Management; 


DOE’s Kansas City Plant 

The Kansas City Plant, a Department of Energy facility, and a major generator of 
waste in the Kansas City area, has reduced the releases and transfers of its four EPA 
33/50 Program reportable chemicals by 98.4 percent since 1988. This has been 
accomplished in cooperation with the Defense Programs Design Agencies by rede¬ 
signing processes and substituting less hazardous or toxic materials. The uses of 
dichloromethane and 1,1,1-trichloroethane have been essentially eliminated. 
Trichloroethane and toluene usage have been reduced by 99 percent and 96 per¬ 
cent, respectively. 5 


5 1996 DOE Pollution Prevention Awards Program: Abstracts of Nominations Selected for National 
Awards. DOE EPIC. 


105 



Chapter 3 - Other Federal Agencies 


■ Appointing pollution prevention program managers in other DOE Secretarial 
organizations that generate wastes, and installing pollution prevention coordina¬ 
tors at field sites; 

■ Decentralizing program implementation, thereby allowing each site to develop 
its own goals (designed to achieve DOE-wide goals) and to fund activities to 
achieve these goals, in a manner consistent with the best practices at that site, 
and; 


■ For FY97, elevating pollution prevention to the status of a “national program” 
so that it will no longer have to compete with mission activities in site 
budgets. 


An Example from DOE’s Return on Investment Pilot Program 

A pollution prevention opportunity assessment was completed on machining pro¬ 
cesses at the ICF Kaiser Hanford Company machine shop. A hazardous waste 
stream consisting of machine coolant that contains persistent and toxic chemicals 
is generated each year at a cost of $138,000. In a retum-on-investment (ROI) 
project funded by the Department of Energy’s Richland Operations Office, a cool¬ 
ant recycling system was selected and installed for a total cost of $61,000; the 
annual cost savings exceeded $121,000 for an ROI of 188 percent. 


In an effort to save taxpayer 
money while reducing waste, 
the Pollution Prevention Ex¬ 
ecutive Board initiated a high 
return-on-investment (ROI) 
pilot program to fund specific 
pollution prevention projects 
with the greatest “payback” 
potential. The ROI program 


was initiated to demonstrate 
the economic benefit of implementing pollution prevention projects, focusing on those 
with high potential for reducing operational costs. Thirteen ROI projects were initi¬ 
ated in 1994 and an additional 21 were funded in 1996. Savings over the next ten 
years are projected to exceed $135 million (in 1996 dollars). Continued pollution 
prevention investments will steadily reduce hazardous and radioactive waste genera¬ 
tion and will reduce the need for unnecessary expenditures for waste treatment, stor¬ 
age, and disposal. The ROI program is now decentralized to the field sites for imple¬ 
mentation. 


In an effort to encourage waste generator accountability, promote waste reduction, and 
provide a source of funds for pollution prevention implementation projects, the Pollu¬ 
tion Prevention Executive Board created a system whereby generators set aside a por¬ 
tion of the costs related to the management of their wastes to be used for funding 
pollution prevention projects. This pilot demonstration will serve as the template for 
similar set-aside programs at other sites. 

Incorporating performance-based incentives for DOE contractors to minimize waste 
streams has significantly energized the pollution prevention program at field sites. 
For FY 1996, Savannah River Operations Office set aside nearly $1.3 million, al¬ 
most ten percent of the total site award fee contract, to motivate its prime contractor 
to implement pollution prevention initiatives that will minimize wastes. Specific 
language was negotiated in the Savannah River annual operations plan that required 
achievement of source reduction through documented waste minimization initiatives 
in order to qualify for fee dollars. These performance objectives were calculated on 


106 


Chapter 3 - Other Federal Agencies 


the basis of levels of waste forecast to be generated and disposed of during the 
upcoming year. 

Likewise, the Oakland Operations Office has succeeded in encouraging pollution pre¬ 
vention activities in non-profit research laboratories operated by the University of 
California. The Lawrence Berkeley and Lawrence Livermore National Laboratories 
have achieved a far greater waste reduction in the past two years than those Oakland 
sites that did not have pollution prevention performance measures in their contracts. 
By incorporating specific pollution prevention expectations in the laboratory perfor¬ 
mance plans, these two sites have reduced waste nearly 25 percent compared to 1993. 

Information/Technology Transfer 


The DOE Pollution Prevention Information Clearinghouse (EPIC) was developed un¬ 
der a joint effort with the DOE and EPA to enhance the exchange of pollution preven¬ 
tion information among federal, state, and local government agencies, as well as with 
industries, academic institutions and the general public. The EPIC system, previously 
a bulletin board system, became a Web site in February of 1995. The system provides 
access to federal and state pollution prevention regulations, DOE pollution prevention 
policy and guidance, special DOE reports and memos, site project summaries, Pollu¬ 
tion Prevention Opportunity Assessments, newsletters, pollution prevention contacts, 
and other periodic reports. 


DOE sponsors an annual Pol¬ 
lution Prevention Confer¬ 
ence; in 1996 it was attended 
by over 400 DOE and con¬ 
tractor personnel. This three- 
day conference included ses¬ 
sions on the following topics: 
model facilities, 

microchemistry, customers/ 


Annual DOE Pollution Prevention Conference 

DOE honored winners of eleven national pollution prevention awards in a cer¬ 
emony on July 10, 1996, in Chicago. Associate Deputy Secretary for Field Man¬ 
agement Donald W. Pearman, Jr., presented awards to DOE employees and con¬ 
tractors as part of the 12th DOE Pollution Prevention Conference. The special 
plaques designed for the awards program were fabricated from recycled computer 
circuit boards by the Kansas City Plant in an innovative process developed in con¬ 
junction with a Texas-based corporation. 


stakeholders, solvents and 

reduction, education and outreach planning, return on investment, energy manage¬ 
ment, decontamination and decommissioning, planning and regulations, environmen¬ 
tal restoration, solid waste, recycling, affirmative procurement, construction and demo¬ 
lition, and the application of standardized approaches to pollution prevention. 


Technology Innovation 

The ongoing and planned cleanup of DOE facilities and systems will generate huge 
volumes of low-level, radioactive, non-putresible waste. Pollution prevention prac¬ 
tices and the development of viable recycling and reuse programs for these materials 
are imperative to constrain the escalating costs of treatment, storage, and disposal. 
The following technology initiatives will help reduce waste generation. 

Recycling slightly radioactively-contaminated metals — carbon steel, stainless steel, 
and nickel — into useful products is a cost-effective alternative to disposal. For ex- 


107 


Chapter 3 - Other Federal Agencies 


ample, stainless and carbon steel can be melted and refabricated into standard-sized 
disposal containers that can replace virgin metal containers currently used. Similar 
research on the viability of other materials (e.g., concrete, depleted uranium) for reuse 
as aggregate or as shielding material is proceeding. 

A cost-effective program for integrated planning, hazard assessments, waste manage¬ 
ment, and use of an innovative technology was implemented at the Formerly Utilized 
Sites Remedial Action Program General Motors site resulting in savings of over $1.6 
million. By aggressively looking for opportunities in a number of key areas in the 
remediation process, waste volumes were reduced from 1,500 cubic yards to 175 cu¬ 
bic yards, wastewater was disposed of at a savings of over $20 per gallon, and the 
impact of the cleanup on ongoing plant operations at the site was minimized. 

Source reduction of waste streams is performed wherever feasible. DOE sites use a 
number of techniques to reduce landfill usage. The Oak Ridge Y-12 site has estab¬ 
lished a goal to achieve total recycling of waste streams such as paper, aluminum, 
and scrap wood. The DOE recycling program was designed to 1) increase the longev¬ 
ity of the landfill disposal sites, 2) reduce costs, 3) conserve energy and natural re¬ 
sources, and 4) comply with federal waste minimization regulations. Due to the suc¬ 
cess of the site-wide paper and aluminum recycling program, some sites have identi¬ 
fied additional waste streams for recycling. These streams include coal ash, automo¬ 
tive wastes from vehicle maintenance, fluorescent bulbs, and toner cartridges as well 
as surplus materials re-routed from disposal to the materials exchange. 

Alternative Solvent Developed 

Synergy CCS ™ is an environmentally derived, surfactant-free, recyclable-Critical 
Cleaning Solvent. The Kansas City Plant, a Department of Energy facility, formu¬ 
lated the solvent in response to a problem of a small manufacturer. The solvent was 
further developed and adopted by Hewlett Packard, and then licensed to a world 
leader in alternative solvent technology, Petroferm, Inc. Synergy CCS™ provides 
a wide range of cleaning capabilities for electrical and mechanical components. Its 
ingredients are listed by the EPA as “approved” and biodegradable. It is derived 
from naturally and annually renewable sources, can be distilled after use, and is 
compatible with most existing cleaning equipment. 

of filtered raw water by recycling a portion of the process condensate effluent, reduc¬ 
ing both raw water usage and process condensate requiring further treatment. Cumu¬ 
lative savings over the projected operating life of the 242-A Evaporator should 
exceed $10 million, greatly exceeding the original $230,000 cost of the modifica¬ 
tion. 

The pollution prevention/waste minimization program at the DOE Pantex Plant in 
Texas and the Savannah River Site in South Carolina received White House Closing 
the Circle Awards in 1996 for achievements in recycling and waste prevention. The 
awards recognized the plants’ outstanding pollution prevention programs, which con¬ 
tain 16 elements ranging from establishment of a plant-wide pollution prevention 


The 242-A Evaporator facil¬ 
ity is part of the Tank Waste 
Remediation System used at 
the Hanford site to reduce the 
volume of radioactive waste 
stored in double-shell tanks. 
Filtered raw water was used 
in the evaporator process, 
contributing to condensate 
eventually requiring treat¬ 
ment. A modification to the 
evaporator replaced the use 


108 


Chapter 3 - Other Federal Agencies 


philosophy and enhanced communication to the creation of employee incentives 
and goal setting. 

Research and Development 

A recent agreement between DOE’s Lawrence Livermore National Laboratory (LLNL) 
and EPA will encourage the development and commercialization of new environ¬ 
mental technology by scientists and engineers. The agreement provides California 
with the services of skilled lab personnel and unique lab facilities to evaluate new 
environmental technologies in hazardous waste management, site cleanup, waste mini¬ 
mization and pollution prevention for certification by California’s landmark Environ¬ 
mental Technology Certification Program. The program provides one-stop scientific 
and engineering evaluation of new technologies to encourage development and speed 
their acceptance. 

Cooperative Agreements/Partnerships 

The Department of Energy’s Office of Industrial Technologies (OIT) continued to 
implement its Industries of the Future strategy. OIT’s strategy is to facilitate partner¬ 
ships with seven materials and process industries — steel, aluminum, metalcasting, 
forest products, glass, chemicals, and refineries. Collectively, these industries use 
over 80 percent of the energy and generate over 80 percent of the waste in U.S. 
manufacturing. Industry will lead the creation of long-term visions and develop 
associated “roadmaps” of technologies needed to get there. The government plays a 
supportive role by facilitating meetings, providing information and planning sup- 
port, and coordinating with government agencies, DOE labs and other partners. The 
technologies which OIT supports are also priorities for industrial customers who 
share in the development cost. This assures not only relevance to industry needs 
but rapid commercial introduction following technical success. 

Acquisition Programs 

The Department’s affirmative procurement efforts are well underway and are bear¬ 
ing fruit. In the 1996 Pollution Prevention Program Plan, the Secretary set a goal to 
increase the procurement of EPA-designated recycled items to 100 percent by the end 
of 1999. In 1994, DOE sites reached a 46 percent affirmative procurement level. 
Guidance to field sites will help to increase affirmative procurement by providing 
useful information, such as a list of sources of recycled items, the relevant Federal 
Acquisition Regulation information, the pertinent DOE Acquisition Regulation infor¬ 
mation, and the latest EPA documents such as Recovered Materials Advisory Notices 
and Comprehensive Procurement Guidelines. 

DOE also maintains recycling programs at Headquarters and at most field sites. In 
1993, the Department recycled approximately one-third of the total sanitary waste it 
generated. DOE developed the Recycled Materials Affirmative Procurement Track¬ 
ing System (ReMAPTS) to track its progress in buying recycled products and to track 
: the recycled content in items purchased. It was developed in response to a request by 
the Deputy Secretary as a way for DOE to show its commitment to Executive Order 

i 


109 




Chapter 3 - Other Federal Agencies 


12870 (superseded by EO 12873). The benefits of using ReMAPTS are that it sum¬ 
marizes data for the Affirmative Procurement Reporting System (APRS), thus provid¬ 
ing greater detail and improved accuracy while requiring less time for compiling year- 
end reports. 


Product Energy Efficiency Recommendations 

In an effort to increase energy-efficient procurement, the Federal Energy Manage¬ 
ment Program (FEMP) released the first seven of its Product Energy Efficiency 
Recommendations, a series of user-friendly, one-page guidelines designed for fed¬ 
eral users. Each recommendation covers one type of equipment and provides the 
reader with an efficiency range representing the upper quartile (25 percent) of the 
market for comparable products, as well as a life-cycle cost analysis example which 
can help the user estimate cost-effectiveness. Relevant conservation tips regarding 
such issues as proper sizing and compatibility issues are also included, as is a refer¬ 
ence section listing contact information for relevant organizations. In addition, 
some of the guidelines make environmental suggestions, such as responsible refrig¬ 
erant policy. An additional 10 recommendations are due out in late fall 1996. 
Brochures are available by calling 1-800 DOE-EREC. 


sites and Headquarters, allowing sites to respond to the 
of computer systems they are using. 


The APRS is a DOE-wide 
electronic data call for those 
required to report on affirma¬ 
tive procurement. The sys¬ 
tem is in the form of diskettes 
(DOS and Windows ver¬ 
sions) or on the Internet 
through the EPIC home page. 
The Internet site is a new de¬ 
velopment for FY 1996 re¬ 
porting and is available to 
DOE sites. Benefits of the 
Internet site include eliminat¬ 
ing the need to mail computer 
disks back and forth between 
data call regardless of the type 


DOE’s Office of Defense Programs and the General Services Administration have 
developed a procurement process for replacing chlorofluorocarbon refrigerants. Sig¬ 
nificant benefits gained by replacing chillers under this Basic Ordering Agreement 
(BOA) include: reducing the use of ozone depleting substances; reducing energy us¬ 
age by replacing older, inefficient chillers with highly efficient chillers as recommended 
by the Federal Energy Management Program; reducing emissions from the generation 
of electricity; and expediting cost-effective procurements for federal agencies. Use of 
the BOA will potentially lead to reductions of 24 million tons of power plant emis¬ 
sions through improved chiller efficiency, and will avoid the use of 6 million tons of 
chlorofluorocarbons. 


Reuse of materials saves money. DOE, like many federal agencies, has an abundant 
supply of formerly used or stored materials that are no longer needed. Reducing the 
inventory can free up warehouse space and help reduce the associated costs of sur¬ 
veillance and maintenance. Some of these materials have considerable value and 
can be reused by other DOE organizations or by others outside DOE. In the past, 
knowledge of the whereabouts and status of potentially useful equipment, clean scrap 
or chemicals has been the biggest obstacle to the transfer of these materials. The 
Department is improving its method of tracking and advertising its assets and mate¬ 
rials through connections to individual sites through the Internet. 

Recognizing that the materials exchange process is a critical step towards pollution 
prevention, the Office of Energy Research is developing a manual for use by pollu¬ 
tion prevention/waste minimization personnel to help select, design, implement, and 


110 


Chapter 3 - Other Federal Agencies 

conduct an internal program 
for excess materials exchange 
at a DOE site. Examples of 
materials exchange programs 
for laboratories, pilot plants, 
and production operations are 
included to identify specific 
features unique to each pro¬ 
gram. 

Pollution Prevention Assess- 
ti ments 

Sandia National Laboratories 
and its partners have devel¬ 
oped a software program, 

EcoSys™, which applies com¬ 
puter science and artificial in¬ 
telligence toward environ- 
i mentally conscious manufac¬ 
turing (ECM) design and pol- 
, lution prevention. EcoSys™ 
provides users with a uniform 
method of analyzing the en¬ 
vironmental impact of manu¬ 
facturing based on product 
design, quantities of materials 

used in processes, and the environmental attributes of material constituents. With the 
software package, a user may input a question regarding a manufacturing process, and 
EcoSys™ provides reasonable choices on how to minimize pollution. 

The Pacific Northwest National Laboratory has developed a framework and tools for 
conducting pollution prevention design assessments. Tools include a guidebook, soft¬ 
ware installation disks, and a user manual. The package will help facilities integrate 
pollution prevention concepts into the underlying principles and procedures of engi¬ 
neering design. 

General Services Administration 

The General Services Administration’s (GSA) pollution prevention strategy focuses 
on purchasing alternative products that do not contain or have reduced amounts of 
hazardous chemicals and educating other federal agencies on purchasing decisions. 

Although GSA does not manufacture or process toxic chemicals, it does use and trans¬ 
fer toxic chemicals offsite; therefore, GSA is committed to achieving a 50 percent 
toxic chemical reduction goal by December 31,1999, by decreasing the agency’s total 
releases and offsite transfers of toxic chemicals. 


Waste Minimization and Reuse at DOE Facilities 

When the Bevalac facility at the Lawrence Berkeley National Laboratory closed 
in 1993, the radiation shielding blocks at the site were no longer needed. These 
huge, concrete, shield blocks of various shapes and sizes have extremely low- 
levels of activation and comprise a total of 19,000 metric tons with a volume of 
13,600 cubic meters. Because of the large volume of these blocks, it would be 
very costly to characterize, transport and dispose of these materials in a DOE burial 
site. Continued use for about 35% of the blocks was located at another DOE site at 
the Brookhaven National Laboratory. Reusing these blocks avoided the high dis¬ 
posal costs and the need to construct new shielding was averted. Savings are esti¬ 
mated at close to $40 million. The remaining blocks are being evaluated for ben¬ 
eficial reuse at other locations. 

Waste minimization, risk reduction, and mortgage reduction are primary goals of 
the Plutonium Uranium Extraction facility (PUREX) deactivation project at the 
DOE Hanford site. Successes to date include the sale of 187,000 gallons of slightly 
radioactive nitric acid for reuse as a product; elimination of approximately 200,000 
gallons of radioactive rinsate through reuse of tank flush waters; elimination of 
approximately 60,000 gallons of radioactive waste water through concentration; 
re-deployment of approximately 3,000 cubic feet of laboratory equipment, and 2.5 
million pounds of chemicals, batteries, oil, and office supplies; strict inventory 
and project management controls to minimize wastes; and disassembly and re¬ 
moval from use of 12 HEPA filters, thereby reducing the total amount of mixed 
waste generated by 169 cubic feet. 


Ill 






Chapter 3 - Other Federal Agencies 


GSA is working with EPA to incorporate environmental and recycling provisions into 
the proposed new EPA Regional Headquarters building in Kansas City, Kansas. In the 
requested building design, a “green rider” specified such features as: high-efficiency 
heating and air conditioning equipment with automated controls; energy conserving 
lighting; endorsement of day lighting; and low-flow plumbing fixtures. Many of these 
items are featured in the proposed Federal Aviation Administration building in the 
Kansas City metropolitan area as well. 6 

GSA uses hazardous substances in facility management applications (e.g., operation 
of storage tanks, cleaning operations, renovation), during new construction, and for 
vehicle maintenance. However, GSA also is using several technologies that eliminate 
or reduce pollution in its operational activities (e.g., reformulated paints, preserva¬ 
tives and cleaning agents, refrigerant recovery units, parts cleaner recovery units, and 
closed loop vehicle wash systems that recycle remaining water after it is separated 
from the wash solution). 7 

GSA has established the New Item Program (NIP) to provide a means to introduce 
new and improved products and services. GSA uses the NIP to promote awareness of 
pollution prevention technologies and to maximize opportunities for customers to 
choose environmentally beneficial products and services. 8 

Buying Green 

GSA has rapidly expanded the scope of environmental products included in the 

national supply system. In addition to office supplies containing recycled content 

materials, a few examples of these products available through GSA are: 

• recycled latex paint 

• low VOC paints 

• alternative fuel vehicles 

• recyclable softballs and baseballs 

• automotive refrigerant recycling equipment. 

cost, and environmental impacts of various cleaning products. The Latex Paints 
Pilot Program will further promote the purchase of environmentally-preferable 
products. 9 


GSA, in partnership with 
EPA, has launched pilot 
programs — including the 
Cleaning Products Program 
and the Latex Paints Pilot 
Program — to test the prin¬ 
ciples outlined in the envi¬ 
ronmentally-preferable 
products draft guidance. 
The Cleaning Products Pro¬ 
gram collected and pub¬ 
lished in the GSA cleaning 
products catalog, informa¬ 
tion on the performance, 


6 Office of the Federal Environmental Executive. Greening the Government: A Guide to Implementing 
Executive Order 12873. (Washington, DC; 1996) p 45. 

7 General Services Administration, Executive Order 12856 Pollution Prevention Strategy. 

8 Ibid. 

9 U.S. EPA, Office of the Administrator. EPA Pollution Prevention Accomplishments: 1994 - Incorporat¬ 
ing Pollution Prevention Into Business Decisions. (EPA 100-R-95-001. Spring 1995.) 


112 



Chapter 3 - Other Federal Agencies 


GS A also is committed to reducing or eliminating products it purchases for other agen¬ 
cies or uses itself that contain hazardous chemicals by reviewing and updating its speci¬ 
fications and by using new technologies that promote pollution prevention. GSA’s 
commodity centers develop specifications for products under their management re¬ 
sponsibility. Each commodity center currently is reviewing its specifications to deter¬ 
mine if hazardous substances can be eliminated from products and/or replaced with 
industry recognized chemical alternatives. In addition, GSA is evaluating the inven¬ 
tory of products that contain hazardous chemicals stocked at each supply distribution 
center. If this evaluation reveals that significant quantities of hazardous chemicals are 
stored onsite, GSA will work with commodity centers to reduce inventories. 10 


Department of the Interior 


Okefenokee Refuge 

The Okefenokee National Wildlife Refuge consists of 396,000 acres, which pro¬ 
vides habitats for a variety of wildlife and recreational opportunities for visitors. 
Since 1995, the Refuge has eliminated the storage and utilization of over 400 
hazardous substances and has decreased its solvent usage by 60 percent through 
modification of its parts and paint cleaning operations. 


The Department of the Interior’s (DOI) Pollution Prevention Strategy commits the 
Department to pursuing a hierarchical approach to pollution prevention, beginning 
with source reduction. DOI’s 
Departmental Manual Part 
518, Comprehensive Waste 
Management, also identifies 
pollution prevention as the 
primary approach to manag¬ 
ing waste activities on all In¬ 
terior-managed lands and fa¬ 
cilities. Under the 

Department’s Pollution Prevention Strategy, each Bureau is responsible for compli¬ 
ance with the requirements of EO 12856, including developing a baseline for measur¬ 
ing reductions in toxic chemicals (using baseline data no later than 1994), developing 
facility plans by December 31, 1995, complying with EO 12856 reporting require¬ 
ments, reviewing and revising specifications, acquisition procedures, and other stan¬ 
dardized documents to reduce the purchase and use of toxic materials, and disseminat¬ 
ing information about pollution prevention techniques and approaches. The strategy 
directs each covered DOI facility to report releases and offsite transfers to TRI by July 
1, 1995, and commits DOI to voluntarily reduce releases and transfers of toxic chemi¬ 
cals by 1999 as specified in Section 313 of EPCRA." 


DOI issued General Guidance on Pollution Prevention and Right-to-Know in response 
to Executive Orders 12856 and 12969. 12 This guidance represents DOI’s commitment 
to the sound management and treatment of solid and hazardous waste and other pollut¬ 
ants on DOI managed lands and facilities. It is embodied in DOFs hierarchical ap¬ 
proach to waste management (pollution prevention, waste reduction, waste manage¬ 
ment and cleanup, and restoration). Additionally, this commitment is also reflected in 


10 General Services Administration, Executive Order 12856 Pollution Prevention Strategy. 

11 U.S. Department of the Interior, Executive Order 12856 Pollution Prevention Strategy. 

12 DOI General Guidance on Pollution and Right-to-Know (September 1995). 


113 




3 - Other Federal Agencies 


source reduction strategies in facility management and the acquisition of environmen- 
tally-preferable products and services. 

The National Park Service (NPS) has developed its own pollution prevention strategy 
for achieving the requirements of Executive Order 12856. The strategy involves pre¬ 
paring pollution prevention plans for each NPS facility and providing public access to 
information on the presence of hazardous and toxic materials used and stored. To 
facilitate compliance with the strategy, NPS sponsored the development of a training 
course to help NPS employees develop pollution prevention plans, conduct opportu¬ 
nity assessments, and comply with EPCRA requirements. 13 

In addition, DOI implemented an Environmental Achievement Award, which recog¬ 
nizes winners at three levels: Bureaus with outstanding performance, employees with 
outstanding performance at each Bureau, and contractors with outstanding performance. 

Examples of DOI’s information transfer initiatives include a series of 30 pollution 
prevention fact sheets to educate DOI facility managers about pollution prevention 
opportunities available for certain activities, such as vehicle maintenance, metal 
working, pest management, building maintenance, concession stands, and others. 
Some DOI Bureaus have developed their own pollution prevention programs and ini¬ 
tiatives. For example, the former Bureau of Mines developed a publication to help 
hardrock and industrial minerals mining and milling facilities reduce or eliminate 
environmental pollution. The report includes worksheets designed to help mining 
facility operators to establish their own pollution prevention programs. 14 

Some parts of DOI are using pollution prevention approaches to their own wastes. 
U.S. Geological Survey (USGS) laboratories generate various waste streams contain¬ 
ing phosphoric, sulfuric, boric, and hydrofluoric acids, potassium dichromate and 
sodium diphenylamine. These chemical uses and wastes have been targeted for a 50 
percent reduction by 1999. The USGS labs have already reduced these wastes through 
process modifications. Prior hazardous waste annual disposal costs averaged ap¬ 
proximately $400,000. To date, reductions have resulted in reduced annual waste man¬ 
agement costs to approximately $225,000. 

National Aeronautics and Space Administration 

In 1994, the National Aeronautics and Space Administration (NASA) developed a 
Pollution Prevention Strategy in compliance with the requirements of Executive Order 
12856. As part of this strategy, NASA committed to prevent or reduce pollution at the 
source whenever possible. Specific activities described in the strategy include com¬ 
mitments to: 


13 U.S. National Park Service, Pollution Prevention and Community Right-to-Know Training Manual. 
Prepared by EA Engineering, Science, and Technology, Inc., under Indefinite Quantities Contract No. 
1443-CX-2000-95-006, Task Order No. 1, for the National Park Service Hazardous Waste Program. 

14 Witkowsky, D.S. Pollution Prevention in Mining and Mineral Processing ■ Waste Assessments for 
Mines and Mills. U.S. Bureau of Mines. 



Chapter 3 - Other Federal Agencies 


■ Review and revise NASA specifications and standards to reduce the use of 
products containing extremely hazardous substances and toxic chemicals; 

■ Use life-cycle cost analysis and source reduction potential as criteria in setting 
project priorities; 

■ Prepare and begin to implement a written pollution prevention plan at all 
major field installations and facilities by December 31, 1995 15 ; and 

■ Strive for a minimum of 50 percent reduction (from a 1994 baseline) for toxic 
chemicals by the turn of the century. 

To reach the 50 percent reduction goal by 1999, NASA is promoting the development 
and implementation of Center-specific pollution prevention plans. As an example, 
NASA Langley Research Center (LaRC) has implemented approximately 30 pollution 
prevention projects throughout its facility. The results of the projects have been sub¬ 
stantial and include: 

■ annual cost savings of approximately $200,000 

■ annual solid and hazardous waste reductions expected to reach 77,000 pounds 

■ air emission reductions of approximately 21,000 pounds per year 

■ capture for recycle of approximately 394,000 pounds of solid waste annually 

NASA LaRC has established a Web site for internal use that contains a new hazardous 
chemical tracking system to control the purchase of hazardous chemicals. The Web 
site also provides current statistics on the facility’s recycling program by organization. 
In addition, NASA developed a guidance manual for its facilities to assist them in 
implementing the requirements of Executive Order 12856 and other related Executive 
Orders. 

U.S. Postal Service 

The U.S. Postal Service (USPS) is committed to the reduction of waste and potential 
pollutants at the source of generation. The USPS Pollution Prevention Strategy in¬ 
cludes using environmental considerations among the criteria by which projects, 
products, processes, and purchases are evaluated. All Postal Service managers are 
required to participate in waste reduction initiatives, including source reduction, re¬ 
use, and recycling activities. The Postal Service’s pollution prevention policy is to: 

■ Encourage the use of non-polluting technologies and waste minimization; 

■ Protect natural resources and the environment through conservation, recycling, 
and reuse of materials internally and externally; 


15 Memorandum to Officials-in-Charge of Headquarters Offices; Directors, NASA Field Installations; 
and Director, Jet Propulsion Laboratory from J/Associate Administrator for Management Systems and 
Facilities regarding NASA Policy for Pollution Prevention. 

115 






Chapter 3 - Other Federal Agencies 


■ Include environmental considerations among the criteria by which projects, 
products, processes, and purchases are evaluated; 

■ Develop environmental responsibilities awareness in postal employees; and 

■ Maintain an environmental quality assurance program. 

USPS is working with EPA 
through an interagency 
agreement to perform pollu¬ 
tion prevention opportunity 
assessments and develop pol¬ 
lution prevention plans for 
eight major facility catego¬ 
ries. Completed plans will be 
included in the Postal Ser¬ 
vice Pollution Prevention 
Handbook for use by facility 
managers and employees in the development of facility-specific pollution prevention 
plans. A variety of initiatives have been developed and implemented that not only 
ensure compliance with the law, but will also establish USPS as a leader in the envi¬ 
ronmental arena. Examples include: 

■ USPS is implementing an Integrated Pest Management program that will 
utilize all appropriate technology and management practices and emphasizes 
non-chemical control techniques over chemical controls. 

■ USPS presented live, interactive media presentations on Environmental 
Alternatives to a Better Vehicle Maintenance Facility and Maintenance 
Initiatives for a Better Environment. Pollution prevention topics in these 
presentations included general pollution prevention initiatives, re-refining oil, 
reductions in EPA’s 17 target chemicals, HVLP painting systems, alternative 
fuel vehicles, pollution prevention training opportunities, aqueous training 
technologies, and landscaping/pesticide management. 

■ The USPS Norman, Oklahoma, Technical Training Facility currently provides 
17 employee training courses in environmentally-related areas. The Waste 
Reduction and Recycling course focuses on the pollution prevention hierarchy. 

■ The USPS New York Metro Area is currently training employees on pollution 
prevention and recycling initiatives, including the development of a “model 
facility” pollution prevention plan for a facility. 1617 

■ USPS and DoD’s Defense Logistics Agency are working together to support the 
USPS refrigerant program to reduce reliance on ODCs in accordance with the 


Waste Minimization and Pollution Prevention at Postal Facilities 

The USPS created a Waste Minimization/Pollution Prevention Program for its 28 
postal sites, resulting in several source reduction initiatives. A waste management 
survey conducted in FY 95, indicated that the Northeast Area Plants reduced the 
quantity of solid hazardous waste generated by over 76 percent since FY 92. The 
sites generated 12,505 gallons of hazardous waste in FY 92 and 2,988 gallons in 
FY 93. Asa result of the source reduction and recycling initiatives, the sites pre¬ 
vented 12,532 tons of non-hazardous waste from being disposed of in municipal 
landfills. (Closing the Circle Awards) 


116 


l6 U.S. Postal Service. United Postal Service Pollution Prevention Initiatives (May 1995). 
17 U.S. Postal Service. Environmental Facts (May 1995). 



Chapter 3 - Other Federal Agencies 


Montreal Protocol and 
the Clean Air Act. 

■ USPS has reduced the 
number of paint spray 
operations and is 
upgrading the remain¬ 
ing operations with 
high volume, low 
pressure (HVLP) 
painting systems. To 
date, 74 paint spray operations have been discontinued and many others 
converted to more efficient systems. Low volatile organic compound paints 
also are being used in the remaining operations. 

■ USPS is now using water-activated adhesives on all stamp products for ease in 
recycling and inks in the stamp production process that meet EPA’s guidelines. 
USPS also includes recycled content material in stamps, retail, and philatelic 
products. 

■ USPS has switched from limited use cardboard mail trays and wooden pallets to 
longer life plastic trays and pallets. USPS purchased two million plastic pallets 
in 1994. USPS also purchased 54,000 plastic mail hampers and 335,800 plastic 
mail containers containing 50 percent recycled content. 

■ USPS maintains the nation’s largest fleet of compressed natural gas (CNG) 
vehicles (2,700 vehicles have been converted). USPS plans to increase the fleet 
of CNG vehicles to about 7,000 by the end of 1995. In addition, USPS is the 
national leader in the use of re-refined oil, with more than 100,000 postal 
vehicles currently using re-refined oil. 

Department of Transportation 

In January 1995, the Department of Transportation (DOT) finalized the Department of 
Transportation Pollution Prevention Strategy, which commits DOT to a comprehen¬ 
sive policy of pollution prevention for its facilities and acquisitions. The strategy 
provides detailed tables summarizing the applicability, major requirements, and key 
deadlines of Executive Order 12856, as well as responsible DOT offices. In addition, 
the strategy directs each covered facility to develop a facility-specific pollution pre¬ 
vention plan to include: facility-specific goals for toxic chemical release reductions; 
an inventory of products used and waste streams containing extremely hazardous 
substances and listed toxic chemicals; evaluation and selection of pollution preven¬ 
tion alternatives; procedures and a schedule for implementation, communication and 
training needs; consideration for involving the community; and procedures for mea¬ 
suring success. In the strategy, DOT established a voluntary 50 percent reduction goal 
in releases of listed toxic chemicals from facilities covered by Section 313 of EPCRA, 
by the end of 1999. The baseline year for this goal is 1994. 


The manager of maintenance operations at the St. Louis Bulk Mail Center replaced 
wet cell batteries with dry cell, maintenance-free batteries, thus eliminating the 
hazards from lead, hydrochloric acid, and hydrogen gas associated with wet cell 
batteries. The switch resulted in an annual savings of approximately $200,000, 
and environmental benefits through the elimination of waste water contaminants 
and acid fume emissions. Due to the St. Louis Bulk Mail Center’s efforts, the use 
of dry cell batteries is being considered for implementation at Postal Service Pro¬ 
cessing and Distribution Centers nationwide (Closing the Circle Awards). 


117 






Chapter 3 - Other Federal Agencies 


To aid DOT facilities in preparing Pollution Prevention Plans, DOT’S Office of Secu¬ 
rity and Administrative Management has issued a Guidance Manual for Preparing 
Pollution Prevention Plans and Pollution Prevention Opportunity Assessments and 
an environmental policy manual. The manual discusses pollution prevention at DOT 
facilities in the context of DOT’s primary pollution prevention objectives: to signifi¬ 
cantly reduce the quantity and toxicity of pollutants released and wastes generated at 
DOT facilities; to make pollution prevention through source reduction an overriding 
factor in all environmental management decisions; and to ensure that all DOT activi¬ 
ties and facilities incorporate pollution prevention concepts by instilling a pollution 
prevention ethic through education and training. 

The Intermodal Surface Transportation Efficiency Act of 1991 (ISTEA) reflects a 
growing recognition that transportation programs must be compatible with environ¬ 
mental goals. ISTEA, which provides federal funding to state and local agencies for 
highway, transit and intermodal projects, includes a number of innovations which help 
states and local areas implement projects that support environmental objectives. States 
must spend a percentage of highway funds on projects such as bicycle and pedestrian 
accommodations, storm water runoff mitigation, historic site restoration and other “trans¬ 
portation enhancements.” Projects are also being funded under a program created to 
carry out air quality improvement projects in nonattainment areas. Highway funds 
may be used for wetland mitigation banks or wetland planning studies. DOT is also 
implementing the National Bicycling and Walking Study, which sets a goal of dou¬ 
bling the percentage of trips made by bicycling and walking. 

DOT is utilizing innovative pollution prevention technologies including materials sub¬ 
stitution, process reengineering, and alternative waste disposal options. Examples in¬ 
clude: 

■ DOT is working to ensure maximum participation in the alternative fuel vehicle 
program by introducing low emission and alternative fuel vehicles into the DOT 
fleet. Most of the headquarters executive fleet vehicles have been converted to 
alternative fuel vehicles. DOT is also promoting the use of environmentally- 
friendly vehicles by the general public. 

■ The U.S. Coast Guard (USCG) is developing of a model consolidated hazard¬ 
ous materials management program. The program is a centralized hazardous 
materials management system, including procurement, distribution, inventory 
and tracking. The USGC is also investigating coating and coating removal 
processes to determine the most economic, efficient and environmentally- 
preferable methods of painting and depainting Coast Guard vessels, buoys and 
lighthouses. The USCG aviation community has developed an aircraft-specific 
Authorized Chemical Use List and Hazardous Materials Tracking system to 
reduce hazardous materials usage and procurement. 

■ The mission of the FHWA’s Turner-Fairbank Highway Research Center 
(TFHRC) includes the development of improved products for highway struc¬ 
ture and materials. These products are used by state highway departments and 


118 


Chapter 3 - Other Federal Agencies 


the highway industry. TFHRC maximizes the use of effective chemicals that are 
not toxic, corrosive or environmentally damaging in the development of 
improved products for highway structure and the highway industry. 

DOT is currently undertaking several research and development projects to decrease 
pollution, including evaluating congestion pricing techniques (e.g., time-of-day re¬ 
lated parking fees, tolls. High Occupancy Vehicle requirements, and permit parking 
zones) to decrease air pollution. DOT is also supporting development and testing of 
clean fuel autos and buses and is working, in cooperation with other agencies, to 
improve transportation and air quality models so planners are better able to evaluate 
transportation system impacts. In addition, DOT has funded extensive research on 
wetlands evaluation and mitigation. 

DOT is working closely with federal, state, and local government agencies to imple¬ 
ment the Clean Air Act Amendment of 1990 and increase coordination of transporta¬ 
tion and land use planning to help reduce emissions. For example, DOT worked closely 
with EPA on its development of regulations for ensuring that transportation plans and 
projects conform to air quality plans. Both agencies have worked with stakeholders to 
address implementation difficulties. DOT and EPA are also cooperating on a pro¬ 
posed public education effort on air quality and transportation. FHWA has worked 
with states and other agencies to improve management of storm water runoff from 
highways. 

DOT has revised the Transportation Acquisition Manual (TAM) to include all envi¬ 
ronmental directives, including Executive Order 12856. The revised TAM was pub¬ 
lished on July 10, 1996. Additionally, several of the Operating Administrations have 
established acquisition practices to limit their use of extremely hazardous substances. 
For example: 

■ The USCG has incorporated pollution prevention in acquisition and procure¬ 
ment in several documents and “green” product procurement awareness is 
promoted in the headquarters and field environmental and acquisition news¬ 
letters. 

■ The FAA has developed several guidance documents which encourage pollution 
prevention and environmentally friendly procurement practices. FAA is 
working to improve its centralized inventory management system and facili¬ 
tate the procurement of environmentally preferred and affirmative procure¬ 
ment items. 

■ In keeping with the Department’s goals for reducing or eliminating unneces¬ 
sary acquisition of products containing extremely hazardous substances or 
toxic chemicals, the FHWA has two regions which are substituting “green” 
products for hazardous ones. The FHWA Central Federal Lands Division 
asphalt testing laboratory is eliminating the use of trichloroethane in asphalt 
testing and the FHWA Eastern Federal Lands Division has replaced chlorinated 
solvents with a biodegradable, nonchlorinated solvent for asphalt extraction 


119 






Chapter 3 - Other Federal Agencies 


"Were going to 
identify what it 
takes to make the 
White House a 
model for 
efficiency and 
waste reduction, 
and then we re 
going to get the job 
done....Before I ask 
you to do the best 
you can in your 
house, I ought to 
make sure I'm 
doing the best I can 
in my house." 

— President Clinton 


testing. The Federal Highway Administration (FHWA) now also requires the 
use of recycled rubber from scrap tires for a portion of asphalt paving projects. 

■ Two of the Maritime Administration’s (MARAD) ready reserve fleets have 
incorporated “green” purchasing practices. One fleet has adopted several 
procurement related policies to help reduce or eliminate the purchase of 
hazardous materials. Management has changed purchasing procedures that 
limit quantities of chemicals on hand to an amount essential to operations, 
thereby reducing releases, deterioration, and waste. Excess or non-usable 
chemicals are being provided to other agencies for use rather than being 
disposed as waste and a vigorous recycling program has been instituted. 
Another fleet has discontinued the use of ozone depleting products, hazardous 
products such as traditionally used solvents, and initiated training for use of 
the freon recovery equipment which was purchased in anticipation of regula¬ 
tory changes. 

The White House 18 

As part of President Clinton’s “Greening of the White House” project, a team of 
experts performed an energy and environmental audit of the White House and 
the Old Executive Office Building. The team identified 50 practical opportuni¬ 
ties to cut waste, improve energy efficiency, and save money. The actions that 
the team recommended and the White House has adopted range from installing 
energy-efficient lighting to minimizing pesticide use and include several model 
initiatives for preventing waste, recycling, composting, and buying recycled prod¬ 
ucts. Examples include: 

■ An internal source-reduction policy for workers at the Executive Complex will 
specify guidelines for reducing paper consumption, using durable products, 
and conserving office supplies, in addition to encouraging greater use of 
electronic communications, such as electronic mail and faxing. 

■ “Grass-cycling” (i.e., leaving grass trimmings on the lawn as mulch instead of 
raking, bagging, and tossing them) will be practiced on the 18 acres of White 
House lawns and gardens. The use of offsite composting facilities to manage 
White House yard trimmings and other organic wastes will be expanded in the 
near future. 

■ Increased recycling throughout the Executive Complex will include improving 
collection mechanisms for materials currently collected (such as placing 
collection bins more prominently) and establishing collection of new materials 
(such as household batteries, polystyrene dishes and utensils from the cafete¬ 
ria, although the cafeteria may eventually move to reusable dishware). In 


18 The White House homepage is located at http://www.whitehouse.gov/WH/EOP/OMB. 

120 



Chapter 3 - Other Federal Agencies 


addition, the First Family collects recyclables, such as paper and aluminum 
cans, in the White House living quarters. 

■ The President’s running track, which is composed of rubber recovered from 
used tires and windshield wipers, is a well-known part of White House efforts 
to encourage “Buying Recycled.” To stimulate markets for recyclables and 
encourage recovery of materials, staff at the Executive Complex will fully 
comply with Executive Order 12873, which directs agencies to purchase 
recycled paper with at least 20 percent post-consumer content. White House 
Staff also will purchase additional supplies made from recovered materials 
whenever possible, using the guidance of EPA’s proposed Comprehensive 
Procurement Guidelines. 

Federal agencies have made impressive strides in the last six years in developing and 
implementing pollution prevention strategies. Spurred by the Pollution Prevention 
Act, the National Energy Policy Act, and a series of Executive Orders dealing with 
recycling, acquisition, procurement, energy efficiency, reporting of releases to the TRI, 
and other pollution prevention issues, federal agencies have begun the laborious pro¬ 
cess of rethinking all the various ways in which their actions impinge upon the envi¬ 
ronment. 

As initial gains are consolidated, new challenges will arise. For example, while 
government purchasing of products with recycled materials has become well-estab¬ 
lished, at least for a select group of product categories, the next step is likely to be an 
expansion of government purchasing into environmentally-preferable products, which 
will involve a broader and more sophisticated assessment of the environmental im¬ 
pacts of various products. Similarly, numerous individual initiatives have been put 
in place in federal facilities across the nation. Using ISO 14000 or EPA’s Code of 
Environmental Management Principles, federal facilities must adopt facility-wide 
environmental management systems that will make pollution prevention a day-to- 
day reality. 




121 







Chapter 3 - Guest Commentary 



The Role of the Federal Environmental 
Executive 

by 

Fran McPoland 

Federal Environmental Executive 
Washington, DC 


It is important that the Federal Government set the example for the American public in the areas of waste 
prevention and recycling, the acquisition of recycled-content products and the institutionalization of environ- 
mentally-preferable purchasing, in order to successfully achieve our national goals. The federal government is 
a major player in the United States as well as the global market place; it has recently been estimated that the 
U.S. government procures $225 billion of goods and services produced annually. 

My role as Federal Environmental Executive was established by EO 12873 Federal Acquisition, Recycling and 
Waste-Prevention (October 20,1993). This Executive Order is responsible for making every Federal agency 
accountable for requirements established by the Resource Conservation and Recovery Act (RCRA) of 1976. 
RCRA provided for the initial framework for Federal waste prevention, recycling and affirmative procurement 
programs. Unfortunately, until the promulgation of this EO, sustained activity in the recycling arena by Federal 
agencies was often not practiced. 

I see three major objectives stated in Executive Order 12873: 

■ reduce the amount of waste material generated at its source 

■ recycle waste generated and reduce the amount landfilled 

H increase the procurement and use of products containing recycled content and environmentally-preferable 
products. 

My aim is to promote further applicable recycling activities, to unite the on-going federal effort in these areas 
and to provide clear direction for their continued success in these efforts. The Office of the Federal Environmen¬ 
tal Executive oversees the environmental programs covering more than 3 million employees, plus a number of 
state, local and contractor personnel nationwide. As a significant consumer of products ranging from office 
supplies, vehicular components, building materials and electronics, the Federal government has a great potential 
for positively affecting the market for products that pose fewer burdens on the environment and human health. 

There are a number of significant successes in this area that I would like to share. Major procuring agencies such 
as the General Services Administration (GSA) and Department of Defense (DOD) have published catalogs of 
environmentally-friendly or “green” products in order to assist their customers purchase products that will make 
a difference. The criteria used to segregate products in these “green catalogs” is based on manufacturer environ¬ 
mental claims; unfortunately the only assurance that one has regarding these claims is the strength of the FTC 
“Truth in Advertising” requirements. 

EPA and GSA recently completed a joint project on products used to clean federal buildings; as a result, EPA has 
developed a matrix system which facilitates the actual decision process as to which products are best suited for a 
specific situation. The Postal Service is currently adopting this draft matrix system into their environmental 


122 




I 


Chapter 


3 - Guest Commentary 


awareness training so that their employees will purchase products that are better for the environment. This is the 
first pilot study within the federal community to incorporate the use of the GSA/EPA environmental attribute 
matrix system agency-wide. 

Agencies across the country are making significant progress in purchasing products with recycled content as 
designated in the EPA Comprehensive Procurement Guide (CPG). Procuring agencies have developed and imple¬ 
mented aggressive Affirmative Procurement Programs in which they purchase products such as paper containing 
20 percent recycled content, retread tires, re-refined lubricating oils, and building supplies and office products 
containing a prescribed recycled content. In fact, the White House practices what it preaches and recently demon¬ 
strated that 98 percent of the copier paper it uses contains the required recycled content. 

Also required by EO 12873 is that federal agencies purchase “environmentally-preferable” products. The EO 
defines “environmentally preferable” as products or services that have a lesser or reduced effect on human 
health and the environment when compared with competing products or services that serve the same purpose. 

Environmentally-preferable products are extremely important since the concept of comparing products and their 
environmental attributes pushes the technological advances for these product lines, thus creating new environmen¬ 
tal benchmarks. In addition, the EO promotes the use of products possessing an environmental advantage within 
the federal government, and thereby ensuring that a market exists for these products and the ensuing technologies. 

A clear and concise definition of “environmentally-preferable” products is still evolving; it is a complex issue with 
many diverse and technical attributes and considerations. So far, a number of agencies have attempted to deter¬ 
mine what “environmentally preferable” means to them and I believe that all of these actions are leading to stron¬ 
ger and more concrete guidelines; progress is being made and more and more issues are being raised to the 
forefront. 

I believe that our technology regarding environmentally-preferable products is in its infancy. At this point, we are 
not even certain of which questions to ask regarding product lines, and in many cases, such as life cycle analysis, 
information is not yet available. And how do we use this information to procure products in a discriminate 
manner? With the continued progress of the manufacturers, the consumers, public interest groups and third party 
certifiers, our information base will evolve so that we can more confidently make informed decisions regarding 
environmentally preferable products in the future. 

Another significant requirement of EO 12873 is recognition of federal agencies for their achievement in meeting 
the objectives of this order; for this purpose, the White House Closing the Circle Award was established. The 
Closing the Circle Award is intended to recognize efforts that make significant contribution for, or impact on, the 
environmental community in specific categories. Waste prevention, recycling, affirmative procurement, environ¬ 
mental innovation, model facility demonstrations, and sowing the seeds for change are all categories under which 
federal agencies can submit nominations. 1 

Last year the Office of the Federal Environmental Executive received 233 nominations form different federal 
agencies for the Award. One of my proudest moments as the first Federal Environmental Executive was the 
invitation by the National Performance Review to submit our 1996 Closing the Circle Award winners for the 
prestigious Vice President’s Hammer Awards. The Hammer Award recognizes federal employees who have pro¬ 
moted “reinventing government” principles in the way their agencies do business. These principles include put¬ 
ting customers first, cutting red tape, empowering employees, getting back to basics, and simply making the 


1 Each of the various award categories are discussed in this chapter. 


! 







Chapter 3 - Guest Commentary 


government work better. The Office of the Federal Environmental Executive submitted 22 nominations to the 
National Performance Review for federal agency employee-teams who have been recognized by this office’s 
Closing the Circle Awards. Examples of federal agencies that have recently received a Hammer include: the 
Affirmative Procurement Team at McChord Air Force Base near Seattle, the St. Louis Maintenance Free Battery 
Team at the St. Louis Bulk Mail Center, and the U.S. Postal Service Northeast Area Processing and Distribution 
Facilities. 

McChord’s Affirmative Procurement Team “Buy Recycled” campaign resulted in both the purchase of over $1.2 
million in products with recovered material and over 9,000 waste-recycling containers produced from recycled 
plastic. Overall, the Affirmative Procurement Team’s campaign yielded an impressive increase in the purchase 
of recycled products; purchases rose from 8 percent in early 1995 to above 85 percent by the year’s end. 

The St. Louis Maintenance-Free Battery Team was commended for successfully reducing the hazards to em¬ 
ployees, achieving an annual savings of approximately $200,000, and realizing the benefits of eliminating wet 
cell battery waste water contaminants and acid fume emissions. The U.S. Postal Service established a compre¬ 
hensive Waste Minimization/Pollution Prevention Program for its 28 postal sites. Their FY95 Waste Manage¬ 
ment survey demonstrated that hazardous waste was reduced by 76 percent and that 95 percent of nonhazardous 
waste was diverted from municipal landfills. 

These examples cited from our Closing the Circle Awards prove that implementing environmentally-conscious 
ideas not only helps the environment, but such actions are potentially economical and efficient to the taxpayer 
and environment itself. Finally, there is a clear Presidential mandate concerning the importance of reduc¬ 
ing unnecessary stress on the environment while implementing processes to allow the government to func¬ 
tion more efficiently. 

I believe that “this relationship is critical in establishing a more intensive environmental consciousness within 
the American public, resulting ultimately in the paradigm shift to a “greener” U.S. culture.” 


124 


Chapter 3 - Guest Commentary 


DOD State of Pollution Prevention Report 

by 

Sherri Goodman 

Deputy Under Secretary of Defense 
Environmental Security 
Department of Defense 
Washington, DC 


DoD’s environmental program has matured considerably over the past decade. Once criticized by environmental 
groups for its apparent indifference to environmental concerns, DoD has steadily won recognition from these 
critics for its environmental performance. We earned their recognition by building a team of over 8,000 environ¬ 
mental professionals and making significant annual investments — now nearly $5 billion per year to meet environ¬ 
mental obligations. We also developed an extensive education and training program; obtained the commitment of 
senior DoD leadership as well as every sailor, soldier, airman, and marine; and revamped the budget policy to 
ensure we comply with all legal requirements. 

The results of this program overhaul have been dramatic. The numbers of legal violations have fallen signifi¬ 
cantly. The volume of hazardous waste disposal has been sliced in half. Recycling programs operate at every 
installation. Species, endangered elsewhere, flourish on our ranges and training areas. 

While proud of these accomplishments, we recognized that we can improve our approach to environmental 
management. We had relied almost exclusively on strict end-of-pipe controls and extensive monitoring to 
comply with established standards and procedures. While this approach was very successful in avoiding legal 
violations, it did not necessarily achieve the best overall environmental performance within the funds we have 
available. Our new goal must be continual improvement of environmental performance though the use of new 
technologies, new partnerships, smart business decisions, and an emphasis on eliminating pollution at its source. 
We are integrating this new approach across all DoD activities from base operations to the entire life cycle of our 
weapon systems. We want to do more than merely meet the established legal requirements. We want to strive 
for the highest performance possible with the funds the American taxpayer provides. 

In adopting this new philosophy, DoD faces two major challenges. Our first challenge involves the traditional 
emphasis on end-of-pipe, command-and-control requirements. Our second challenge involves the current fed¬ 
eral budgeting process which focuses on meeting short-term legally-mandated requirements. DoD is taking on 
both of these challenges by creating new innovative partnerships with industry, regulators, and the public. 

As the first step in implementing our new philosophy at base operations, we revised our policy directives, 
instructions, and budget development guidance to encourage the use of pollution prevention projects as the 
preferred method to achieve compliance, and to implement a longer term investment strategy. We also inserted 
these messages into the education programs for environmental engineers and other professions whose activities 
or decisions affect environmentaloutcomes. And we required every installation to develop a plan to identify and 
assess long-term pollution prevention opportunities. 

We initiated a pilot project with EPA, called ENVVEST, to demonstrate at our installations that alternative envi¬ 
ronmental management strategies can produce greater environmental quality at equal or lower costs. Similar to 
EPA’s Project XL for the private sector, the concept of ENVVEST is simple - provide flexibility to a military 

















Chapter 3 - Guest Commentary 


installation and the local regulators, with stakeholder involvement, to develop specific projects to protect human 
health and achieve greater overall environmental performance, within the installations’ original budget. Through 
ENVVEST, we hope to trade paperwork for performance. 

One of our most effective initiatives for improving environmental performance involves the adoption of pharmacy 
procedures and other state-of-the-art business practices to manage hazardous materials. A single office at each 
installation controls all purchases, maintains all stocks, distributes materials to the shops when required and in 
quantities sufficient for the immediate task, and disposes of all excess materials. Implementation of this simple 
management technique has greatly improved our environmental performance and reduced purchases and disposal 
costs. 

We are also working to adopt this new philosophy in the operation and maintenance of existing weapon systems, 
which accounts for most of the hazardous materials managed by DoD. Most of this hazardous material use is 
required by tens of thousands of military specifications and standards. Our strategy is to revise or eliminate the 
use of standardized documents requiring hazardous material use. Changing these standardized documents is 
not an easy or inexpensive proposition. That’s why DoD is working to focus its pollution prevention efforts on 
those weapon systems, associated maintenance processes, and standardized documents that drive the bulk of our 
toxic releases using the results of DoD’s recently published Toxics Release Inventory. 

We are also applying our new philosophy to the way we buy, design, and build new weapon systems. We are 
putting in place new acquisition policies and procedures that require the program manager to analyze the system’s 
life cycle environmental effects in testing, production, deployment, and disposal and to identify opportunities for 
pollution prevention prior to any major decision. And we are not limiting these efforts to our own installations. 
We are also working with our major contractors to reduce toxic chemicals used in manufacturing processes to 
build or maintain our weapon systems. 

This is an exciting time for environmental professionals. Environmental challenges have grown significantly 
over the past few years. New partnerships, smart business decisions, new technologies and perhaps most of all, 
a preventive approach will ensure we protect human health and the environment for generations to come. 


126 


Chapter 3 - Guest Commentary 


Energy and Environment: Common Ground on 
tHe Bridge to the Future 

by 

Christine Ervin 

Assistant Secretary for Energy Efficiency and Renewable Energy 
Department of Energy 
Washington, DC 

Christine Ervin has recently joined the President’s Council for Sustainable Development as Senior Advisor on Cli¬ 
mate. 

The 19th century English poet Matthew Arnold wrote of “wandering between two worlds, one dead, and the other 
powerless to be bom.” We are faced with such a dilemma today. Our long-held environmental and energy paradigm 
represents the past, and another rapidly emerging paradigm represents the future. 

Our past behavior is largely a legacy of an extraction economy where fresh resources were appropriated without 
regard for limit, and where new resources were available just over the next horizon. Many now believe that this 
paradigm is outmoded and remains with us primarily because of inertia. In contrast, an emerging paradigm 
views limited planetary resources as gifts to be efficiently used, for this and for all future generations. The press 
of population and increasing expectations and levels of affluence highlight the need to change our traditional 
world view. 

The world has grown by nearly half a billion people (over 8 percent) since the Clean Air Act Amendments of 1990 
were enacted. During that same 5-year interval, the population of the United States increased by 13.9 million 
people, from 249.9 million to 263.8 million (+5.6 percent). According to Sir Robert May, an American currently 
working in London as the Chief Scientific Advisor to the United Kingdom government and Head of Office of 
Science and Technology, “humans currently appropriate between 1/4 and 1/2 of the productive capacity of the land 
to their own ends; and about 1/10 of the productive capacity of the oceans.” What matters is our numbers, AND the 
resource intensity of our planetary footprints. A baby born in the United States is likely to consume Earth’s re¬ 
sources at a rate 3 times that of a baby born in Italy, 13 times more than one born in Brazil, 35 times more than for 
one born in India, 140 times more than one born in Bangladesh or Kenya, and 280 times more than one born in 
Rwanda, Haiti or Nepal. Over the next decades, we will work to raise the standard of living in the developing 
nations; equity and justice demand that we do so. Ecological and economic realities demand that we use fundamen¬ 
tally new patterns of development. 

Since passage of the National Environmental Policy Act in 1969, we have made great progress in cleaning the 
environment and resolving some of the most noticeable insults. But by focusing on the most severe pollution, we 
have unwittingly short-changed our longer-term thinking. Consequently, while we can expect some additional 
benefits from legal “command and control” approaches, we can also expect greatly increasing compliance costs. 
Currently, compliance costs are estimated at $150 billion per year, and are expected to increase towards $200 
billion per yearby the end of this century. We already have made the “easy fixes,” eaten the “low-hanging” fruit. 
The existing paradigm for environmental protection is approaching diminishing returns. 

As the Economist noted: “The production and use of energy does more environmental damage than any other 
activity.” And the world’s appetite for energy in the new millennia will increase dramatically. In this decade, we 
will invest over $1 trillion in new energy infrastructure and that trend is expected to continue over the next 



127 










Chapter 3 - Guest Commentary 


several decades. Fortunately, we are fostering an alternative. Instead of controlling the effects of pollution after it 
is already generated, we are taking a new approach to pollution, one that is familiar to the public health community 
but one that is just emerging in the environmental field: prevent it from occurring in the first place. 

If we are imaginative and bold, we can forge this new paradigm and a world that until now has been largely power¬ 
less to be born. In this world, “lean and green” manufacturers will see environmental regulations only as a backstop 
on the playing field of pollution prevention, comprehensively intelligent design and competitive advantage. Since 
energy is vital to manufacturing, energy efficiency and renewable sources of energy must play a far greater role. 
Solutions will be far more comprehensive and systematic than today’s single-pollutant, single-media focus. DOE’s 
Office of Energy Efficiency and Renewable Energy is helping forge this future and is leading the nation to a stronger 
economy, a cleaner environment, and a more secure future through development and deployment of sustainable 
energy and manufacturing technologies. 

For example, DOE’s Industries of the Future effort is helping seven U.S. primary industries chart technology 
roadmaps for the future. Recently, the Forest Products industry’s environmental compliance costs were estimated 
at $11 billion. With the help of DOE-catalyzed technology roadmaps, the industry looked comprehensively at 
their entire process and redesigned it to produce enhanced product with much less pollution. Using the new 
approach, compliance costs are now estimated at about $3 billion, a 70 percent reduction. 

In addition, our RD&D energy programs are aimed at preventing pollution now and for the next century: Compact 
Fluorescent Lamps; Electronic Ballasts; E-Glass; efficient Flame Retention Head Oil Burners; Computerized Building 
Design Tools; high-efficiency Refrigerator Compressors; Photovoltaics; Geothermal Heat Pumps; AC Electric Au¬ 
tomotive Drive Trains (GM’s new electric car, the Impact); Sulfur-Lamps (now used by the Smithsonian’s Air and 
Space Museum). These investments not only help the environment by preventing the emission of millions of tons of 
pollution, they lower the cost of using energy, thereby saving consumers and businesses billions of dollars a year. 
The national wealth created by just a handful of these technologies has more than paid for all of the funding required 
to operate the Office of Energy Efficiency and Renewable Energy since 1978. 

Yet for these and other technologies to reach their full promise, we need to engage the imagination and deploy¬ 
ment resources of the private sector and all federal agencies. We need new strategies to link Technology Policy 
with Environmental Policy to convert increasing challenges into market opportunities. We need to find effective 
ways to stimulate technological innovation as an environmental tool. We need to move our legal and institutional 
structures in directions that accommodate and nurture innovation. We need policies that encourage comprehen¬ 
sively integrating environmental considerations into the means of production. The world market for environmen¬ 
tal and efficiency technologies is estimated at $800 billion by the middle of the next century. The future will 
belong to those who best integrate resource efficiency into product and factory. 

Buckminster Fuller summarized the dilemma of our collective inertia on the first page of his Operating Manual 
for Spaceship Earth, where he described a shipwreck and a shortage of lifeboats. A floundering, but aspiring, 
designer grasps for a piano crate for flotation to save her life. Safely back on shore, the designer is given the task 
of designing lifeboats. Should her designs look like piano crates based on successful past experience? Or should 
her designs look comprehensively at the problem, and set aside design pathways that descend from expediency, 
matters of convenience and habit? 

We must not cling to piano-crate thinking. Energy choices made in the United States over the last several decades 
in manufacturing, transportation, and construction significantly effect today’s environment. Likewise, energy choices 
and investments made today will have profound consequences for future environmental quality. 


128 


Chapter Four 

Preventing Pollution at tlie 
State and Tribal Level 


■ Overview of State Programs 

■ State Program Activities 

■ Pollution Prevention on Tribal Lands 

■ Guest Comments: 

Linda Bray Rimer, North Carolina 
Department of Environment 

Mary A. Gade, Illinois Environmental 
Protection Agency 

Andrea Farrell, The National Pollution 
Prevention Roundtable 






Chapter 4 - States and Tribes 








Chapter 4 - States and Tribes 


Introduction 

State-based environmental programs have made a unique contribution to pollution 
prevention through their direct contact with industry and awareness of local needs. 
Whether they target specific industries for outreach and technical assistance or seek to 
transform the bureaucracy to accept the pollution prevention ethic, states continue to 
lead the pollution prevention movement. More recently, Native American tribes have 
also begun establishing pollution prevention programs. 

Assessment of Changes From 1991 to 1997 

Since the 1991 pollution prevention progress report, states have continued to develop 
and refine their pollution prevention programs. Native American tribes have also 
begun establishing pollution prevention programs. Table 4-1 summarizes the activity 
levels in different aspects of program status in 1991 and 1997. 

One of the most dramatic changes since the 1991 report is the decline of pollution 
prevention activity in the legislative arena. Legislative activity peaked in 1990, with 
11 states enacting legislation to promote pollution prevention. While states contin¬ 
ued to legislate facility planning and to enact other legislation though the end of 1991, 
only a handful of states have enacted new legislation since then. Furthermore, no 
additional states have enacted facility planning legislation since the end of 1991. 

A trend that has continued since the last report is the development and implementa¬ 
tion of state pollution prevention strategies. During 1991, approximately half of the 
states had convened work groups, advisory committees, and task forces to develop 
state pollution prevention strategies. 1 Today, most states have moved from the strat¬ 
egy development phase into implementation. 

At the time of EPA’s last report, most state programs were focused on teaching busi¬ 
nesses about pollution prevention through outreach and technical assistance. In doing 
so, the states sought to instill the pollution prevention ethic throughout the business 
community. When studying the barriers to implementing pollution prevention, how¬ 
ever, many states realized that sometimes the state regulatory structure was hampering 
the implementation of prevention activities. Thus, many states have increased efforts 
to integrate pollution prevention into the state bureaucracy. Initiatives have included 
training state and county regulators in pollution prevention, reviewing state regula¬ 
tions to identify barriers to pollution prevention, increasing referrals from the regula¬ 
tory program to the technical assistance program, and incorporating pollution preven¬ 
tion considerations into permits, notices of violation, and settlement agreements. 


1 Based on data reported through the Pollution Prevention Information Tracking System (PPITS), a 
data base that houses the most up-to-date information on state grants awarded by EPA’s Pollution 
Prevention Division. PPITS stores information from initial grant proposals and is continually updated 
with new information from semiannual progress reports. 




131 






Chapter 4 - States and Tribes 

Table 4-1. Pollution Prevention Program Status in 1991 and 1997 


1991 Program Status 

1997 Program Status 

States 

Legislation 

Widespread activity 

Little new legislation since 1991 

Pollution Prevention Policy 

Development phase 

Implementation phase 

Outreach Focus 

Industry 

Industry and regulatory agencies 

Measurement 

Little measurement under way 

States developing measurement 
methodologies 

Pollution Prevention Networks 

Emerging 

Continuing to emerge 

Tribes 

Pollution Prevention Programs 

Few, if any, tribal programs 

Tribal programs and networks 
emerging 


The development of methods to measure pollution prevention progress and to evaluate 
state program effectiveness has emerged as an important new trend. Both the states 
and EPA are struggling with selection of the best approach. Since 1991, several states 
have increased their emphasis on measurement efforts. For example. North Carolina 
received a 1994 EPA grant to develop a pollution prevention measurement methodol¬ 
ogy for Region IV. Elsewhere, for example in Alabama, Massachusetts, Erie County 
(NY), Iowa, and Minnesota, efforts are under way to measure the success of programs. 
Measuring the success of specific projects in preventing pollution is proving a much 
simpler task than measuring the success of state programs as a whole. Some examples 
of the measures of success of specific projects are cited in this chapter. Program 
measurement remains one of the greatest challenges to all states, perhaps because the 
structure of existing regulatory programs and their measurement systems do not neces¬ 
sarily lend themselves to measuring source reduction collectively. 2 In 1996, EPA 
targeted its Pollution Prevention Incentives for States (PPIS) grants to help states de¬ 
velop measurement methodologies. 

Another emerging trend is the attempt of state agencies to build pollution prevention 
networks throughout the state. Agencies that coordinate pollution prevention activi¬ 
ties are working to develop partnerships with universities, National Institute for Sci¬ 
ence and Technology (NIST) Manufacturing Extension Partnerships (MEPs), Small 
Business Development Centers (SBDCs), local governments, nonprofit organizations, 
and state regulators. In addition, the states have sought to involve community groups 
in preventing pollution in economically disadvantaged neighborhoods. The 1997 grants 
cycle further supported this effort to develop networks and create partnerships. 


132 


2 For a discussion of the larger issue of how pollution prevention can be measured on a national scale, 
see Chapter 7 - Measuring Pollution Prevention - in this report. 








Chapter 4 - States and Tribes 


States have also recognized 
that many of their pollution 
prevention concerns cross 
state boundaries. Therefore, 
many states are working to¬ 
gether in geographically- 
linked networks to share re¬ 
sources and expertise. One 
example of a regional net¬ 
work is the Northeast Waste 
Management Officials’ As¬ 
sociation (NEWMOA). 


Regional Networking: NEWMOA 

NEWMOA is a non-profit interstate association of pollution prevention, hazardous 
and solid waste, and waste site cleanup program directors from state environmental 
agencies in New England, New Jersey, and New York. It was formally recognized 
by EPA in 1986. NEWMOA provides support services to its eight member states to 
enhance state capabilities, facilitate program and policy development, and foster 
communications. NEWMOA helps states articulate and promote regional positions 
and strategies for environmentally sound and effective waste management and pol¬ 
lution prevention programs. 


EPA’s Office of Pollution Prevention and Toxics (OPPT) also is convening the Media 
Association P2 Forum, which consists of program directors that sit on state waste, 
water, and air associations and members of the National Pollution Prevention 
Roundtable. Pollution prevention can be a common thread for single-media state 
programs, and the quarterly forum meetings provide a rare opportunity for these 
organizations to discuss pollution prevention. Additionally, OPPT will be commenc¬ 
ing a pollution prevention project group as part of the Forum on State and Tribal 
Toxics Action (FOSTTA). FOSTTA serves as a mechanism for state and tribal offi¬ 
cials to cooperate in addressing toxics related issues and to improve communication 
and coordination among states, tribes, and EPA. 

This chapter focuses on current state and tribal pollution prevention activities, begin¬ 
ning with an overview of state programs. The next section characterizes activities 
common to state programs, followed by a description of the pollution prevention ac¬ 
tivities under way on tribal lands. The final section discusses challenges facing state 
and tribal programs in the upcoming years. 


Overview of State Programs 


State pollution prevention 
programs vary widely in 
scope. Noting the differing 
needs of the states, EPA de¬ 
signed its PPIS grants to be 
very flexible. To receive 
funding under PPIS, states 
are required to assess local 
needs and design a program 
to meet those needs. The 
grant program also encour¬ 
ages the states to combine 
forces with other state orga¬ 
nizations actively promoting 


National P2 Roundtable 

The National Pollution Prevention Roundtable (NPPR) is the largest membership 
association of state, local and tribal government programs devoted solely to sup¬ 
porting efforts to eliminate or reduce pollution at the source. The Roundtable’s 
affiliate membership includes representatives from private industry, nonprofit or¬ 
ganizations, trade associations, federal agencies and academic institutions. For 
more than ten years, the Roundtable has fostered the development, implementa¬ 
tion, and evaluation of pollution prevention programs. The National Roundtable’s 
state and local government members located in every state provide pollution pre¬ 
vention information to thousands of industrial, commercial and agricultural facili¬ 
ties each year. 


133 





Chapter 4 - States and Tribes 


pollution prevention. These directives, together with the varied ways proactive states 
have approached pollution prevention independent of EPA, have resulted in a varied 
array of state programs. This section describes the legislative mandates, organiza¬ 
tional structure, and approaches of the state pollution prevention programs. Much of 
the information in this chapter was gathered by the National Pollution Prevention 
Roundtable. 


Legislation 3 

Slightly more than half of the states (30 total) have enacted legislation that promotes 
pollution prevention. While most of this legislation was enacted between 1989 and 
1991, a few states passed pollution prevention bills as early as 1987. For example, 

Louisiana enacted the 1987 

Michigan's Pollution Prevention Legislation 

Michigan’s 1987 Waste Reduction Assistance Act, created a non-regulatory tech¬ 
nical assistance program in the Department of Commerce designed to: 

■ Create an information clearinghouse 

■ Provide on-site waste audits 


■ Establish a grant program 

Michigan’s Waste Minimization Act, created an Office of Waste Reduction in the 
Department of Natural Resources. The law required this office to: 

■ Encourage waste reduction in the regulatory program 

■ Explore opportunities for incorporating waste reduction into permitting 

■ Document waste reduction efforts in environmental impact statements 

■ Study the value of imposing statewide reduction goals 

■ Publish an annual report of waste reduction efforts 


Waste Reduction Law, which 
requires certain waste gen¬ 
erators to report on both pre¬ 
vious and planned waste re¬ 
duction efforts. Similarly, 
Michigan enacted legislation 
in 1987 to establish pollution 
prevention staff in two state 
agencies, one regulatory and 
one non-regulatory. 

Following these early efforts, 
28 states enacted legislation 
promoting pollution preven¬ 
tion between 1988 and 1991. 
Legislative activity peaked in 
1990, when 11 states enacted 
legislation. From 1992 to 


March 1994, only a handful 

of states, including Georgia, Colorado, Pennsylvania, and Virginia, enacted new pol¬ 
lution prevention legislation. The scope of state laws range from requiring facilities 
to submit pollution prevention plans, to levying fees on waste generation, to estab¬ 
lishing pollution prevention programs and state policies. 

Fees 

Some states have authority to levy fees on hazardous waste generators. Fees collected 
generally are used to support state pollution prevention efforts. States with legislation 
regarding fees frequently tax hazardous waste generators based on the volume and/or 
destination (e.g., recycling, treatment, storage, or disposal) of the waste. For example, 
in its 1991 Amendments to Hazardous Waste Management Statutes, Arizona estab- 


3 National Pollution Prevention Roundtable (NPPR). The Source: The Ultimate Guide to State 
Pollution Prevention Legislation (July 1996). Available from NPPR: (202) 466-7272. 


134 




Chapter 4 - States and Tribes 


lished a Hazardous Waste Management Fund, to be supported through the following 
contributions: 

■ Facilities that ship hazardous waste off site pay $ 10/ton. 

■ Facilities that dispose of hazardous waste pay $40/ton. 

■ Facilities that retain their hazardous waste for onsite disposal pay $4/ton. 

With its 1990 Toxics Use Reduction Act, Massachusetts established base fees for com¬ 
panies of varying sizes. The base fee increases by increments of $300 per listed toxic 
substance used and is periodically adjusted. Similarly, the Minnesota Toxic Pollution 
Prevention Act assesses a $150 fee for each toxic chemical reported by a facility; $500 
if total facility toxic release is under 25,000 pounds annually, and two cents a pound up 
to a maximum of $30,000 for facilities releasing more than 25,000 pounds. 

Establishment of Pollution Prevention Programs/Policies 

Many states have enacted legislation to establish pollution prevention programs or to 
institutionalize state waste reduction policies. Virginia passed legislation in 1993 that 
established pollution prevention as the preferred waste management option. The 1993 
Amendment to the Waste Management Act called for the state to remove barriers to 
pollution prevention and provide encouragement and assistance for such activities. 

Many states have developed a formal pollution prevention strategy or policy state¬ 
ment, often one that is consistent with the environmental protection hierarchy of the 
federal Pollution Prevention Act. For example, Colorado’s 1992 Pollution Prevention 
Act declares that “it will be the state’s policy that pollution prevention is the environ¬ 
mental management tool of first choice. Only pollution that cannot be prevented can 
be recycled, treated, or disposed” and only in an environmentally safe manner. Other 
states have developed formal pollution prevention strategies that articulate a mission 
or goals, objectives, and an implementation schedule. New Hampshire’s Strategic 
Plan and Pollution Prevention Strategy , for example, describes the state’s goals and 
recommended actions on specific issues in the areas of program infrastructure, target¬ 
ing activities, outreach, and regulatory integration. 

When developing their pollution prevention strategies, some states have convened 
task forces or advisory committees to gain input from industry and other interested 
parties. Florida, for example, formed a Pollution Prevention Council within the De¬ 
partment of Environmental Regulation. The Council, composed of representatives 
from business, industry, agriculture, government, and environmental groups, issued a 
report that included recommendations on: statewide pollution prevention guidelines; 
evaluation of opportunities, incentives, and the potential for cooperation; and recom¬ 
mendations on permanent sources of funding for the program. Similarly, Georgia’s 
Environmental Protection Division formed a Pollution Prevention Strategy Task Force 
to develop a strategy for integrating pollution prevention into the state’s regulatory 
programs. 


Many states have 

enacted 

legislation to 

establish 

pollution 

prevention 

programs or to 

institutionalize 

state waste 

reduction 

policies. 


Organizational Structure 


135 








Chapter 4 - States and Tribes 


EPA defines a state 
pollution 
prevention 
program as all 
those 

organizational 
units that work 
togetherto 
implement the 
state's pollution 
prevention agenda. 


Several types of organizational units can make up a state pollution prevention pro¬ 
gram, ranging from offices in state regulatory agencies, to university departments, to 
nonprofit foundations, to local governments. Additionally, the NIST MEPs and a 
number of the SBDCs provide pollution prevention services. Even within regulatory 
agencies, different types of organizational units can implement the pollution preven¬ 
tion activities. For example, pollution prevention staff may be located within the 
media programs (air, water, solid/hazardous waste). Other staff may be completely 
separate from the media programs, located, for instance, in a state commissioner’s 
office, special projects division, or pollution prevention division. Some states imple¬ 
ment pollution prevention activities through an ombudsman or small business techni¬ 
cal assistance program. 

Most states coordinate pollution prevention activities through a non-media office in 
the state environmental regulatory agency. For example, Maine relies on its Office of 
Pollution Prevention within the state Department of Environmental Protection. While 
some states may implement the entire pollution prevention program through this type 
of office, other states will use several organizational units to fulfill their mission. For 
instance, Alabama implements its program through three organizational units: a non¬ 
media office in the environmental regulatory agency, the Ombudsman/Small Business 
Technical Assistance program, and the Waste Reduction and Technology Transfer 
(WRATT) Foundation. Table 4-2 identifies which organizations each state uses to 
implement its pollution prevention program. 


Table 4-2. Components of State Pollution Prevention Programs 4 


State Regulatory Agency 


Non-Regulatory Agency 


Local Gov’t 


State 

AL 

Media 

SBTAP 

✓ 

Non-media 

✓ 

University 

MEP NGO 

✓ 

Agency 

AK 

✓ 


✓ 




AZ 


✓ 

✓ 


✓ 

✓ 

AR 



✓ 




CA 

✓ 


✓ 

✓ 

✓ 

✓ 

CO 



✓ 

✓ 



CT 


✓ 

✓ 


✓ 



4 Source: The Pollution Prevention Yellow Pages. National Pollution Prevention Roundtable, September 1995. For this table. Media refers to a 
pollution prevention staff in the air, solid/hazardous waste, or water program of the state regulatory agency. It includes Air Quality Small Business 
Assistance Programs. SBTAP refers to staff in small business technical assistance programs or an ombudsman’s office in the state regulatory 
agency. Non-media refers to staff in non-regulatory, non-media offices of state regulatory agencies. Universities refers to any pollution prevention 
technical assistance or education program in a state or private university. MEP refers to NIST Manufacturing Extension Partnership centers. NGO 
refers to private, nonprofit agencies (nongovernmental organizations) within the state that provide pollution prevention services. Local refers to 
local pollution prevention programs (either city or county). These programs may be based in a regulatory or non-regulatory setting. 

136 









, ^ // A ■ \ 
v Wa 




Chapter 4 - States and Tribes 

Table 4-2. Components of State Pollution Prevention Programs (Cont’d) 


State Regulatory Agency 

Non-Regulatory Agency 

Local Gov’t 

State 

Media 

SBTAP 

Non-media 

University 

MEP NGO 

Agency 

DE 



✓ 


✓ 


FL 


✓ 

✓ 

✓ 


✓ 

GA 


✓ 

✓ 

✓ 

✓ 


HI 

✓ 


✓ 




ID 



✓ 




IL 



✓ 

✓ 

✓ 

✓ 

IN 


✓ 

✓ 

✓ 



IA 

✓ 


✓ 

✓ 

✓ 


KS 



✓ 

✓ 5 

✓ 


KY 




✓ 

✓ 


LA 


✓ 


✓ 



ME 



✓ 




MD 


✓ 

✓ 


✓ 


MA 

✓ 

✓ 

✓ 

✓ 

✓ 


MI 



✓ 

✓ 

✓ 

✓ 

MN 


✓ 

✓ 

✓ 

✓ 


MS 


✓ 

✓ 




MO 


✓ 

✓ 




MT 

✓ 

✓ 


✓ 



NE 



✓ 



✓ 

NV 




✓ 6 



NH 


✓ 

✓ 




NJ 



✓ 

✓ 



NM 




✓ 

✓ ✓ 


NY 


✓ 

✓ 

✓ 

✓ 

✓ 

NC 



✓ 

✓ 



ND 



✓ 

✓ 




5 The University of Kansas operates a Small Business Assistance program. 

6 The University of Nevada at Reno houses the offices of the Nevada Small Business Development Center. 

137 









Chapter 4 - States and Tribes 

Table 4-2. Components of State Pollution Prevention Programs (Cont'd) 



State Regulatory Agency 

Non-Regulatory Agency 

Local Gov’t 

State 

Media 

SBTAP 

Non-media 

University 

MEP NGO 

Agency 

OH 



✓ 

✓ 

✓ 

✓ 

OK 



✓ 


✓ 


OR 

✓ 


✓ 




PA 


✓ 

✓ 

✓ 

✓ ✓ 

✓ 

RI 



✓ 

✓ 



SC 



✓ 

✓ 

✓ 


SD 



✓ 




TN 

✓ 

✓ 

✓ 

✓ 



TX 

✓ 

✓ 

✓ 

✓ 



UT 

✓ 

✓ 

✓ 




VT 



✓ 


✓ 


VA 



✓ 

✓ 

✓ 


WA 

✓ 

✓ 

✓ 



✓ 

WV 

✓ 



✓ 



WI 

✓ 

✓ 

✓ 

✓ 



WY 

✓ 







Program Approaches 

State programs may undertake a variety of activities to achieve their pollution pre¬ 
vention goals. In general, four approaches are used by the states to implement their 
programs: technical assistance/outreach, mandatory facility planning, regulatory in¬ 
tegration or coordination, and voluntary partnerships. States often use a combina¬ 
tion of all three of these approaches. 

Technical Assistance/Outreach 

The first approach is to provide technical assistance, outreach, and training to businesses in 
the hope that they will initiate pollution prevention activities. Many states favored this 
approach when beginning their programs based on the assumption that businesses would 
reduce or eliminate pollution voluntarily if they received proper training and education 
on the cost savings associated with pollution prevention. For example, eight of the first 
nine grants awarded under EPA’s PPIS grant program in 1989 focused at least in part on 
technical assistance, outreach, and training. 


138 











Chapter 4 - States and Tribes 


Mandatory Facility Planning 

The facility planning approach was used by states such as California, Massachusetts, 
New Jersey, and Washington in the early development of pollution prevention pro¬ 
grams. Through legislation, these states required certain industrial facilities to study 
pollution prevention opportunities in their operations and report on their findings. 
While the laws do not require reporting facilities to implement specific activities 
identified in the opportunity assessments, many do require facilities to explain their 
rationale for not implementing all viable opportunities identified. This approach 
assumes that once facilities have examined pollution prevention opportunities, they 
will implement these activities due to the potential cost savings. 


States are 
increasingly 
attempting to 


Regulatory Integration 

The states are increasingly attempting to integrate pollution prevention throughout 
their regulatory programs. In doing so, states do not mandate pollution prevention, 
but they attempt to remove bureaucratic barriers to pollution prevention and encour¬ 
age pollution prevention in the regulatory process. In 1994 and 1995, 20 percent of 
PPIS grant awards were for regulatory integration. Examples of regulatory integration 
activities include: 

■ Reviewing regulations to reduce barriers to pollution prevention. 


integrate pollution 
prevention 
throughout their 
regulatory 
programs. 


■ Referring facilities to the technical assistance program from the regulatory 
program (e.g., after inspections, when facilities apply for permits, in notices of 
violation). 


■ Facilitating pollution prevention in air, water, and waste permits. 

■ Incorporating pollution prevention into settlement agreements for violations. 

■ Training state/county regulatory staff to understand basic pollution prevention 
concepts and identify opportunities to minimize the cross-media transfer of 
pollutants during regulatory activities. 

■ Experimenting with facility-wide permits and/or multimedia inspections. 


Voluntary Programs 

Many states have established voluntary programs (often modeled after EPA’s volun¬ 
tary partnerships) to promote prevention. For example, in Texas the Clean Texas Star 
and the Clean Industries 2000 have received wide participation. Begun in August 
1995, Clean Texas Star is a voluntary program intended to reduce the generation of 
non-hazardous industrial waste and encourage recycling by Texas businesses, schools, 
and other institutions. The program sets measurable goals for reductions and recycled 
content purchases, and provides public recognition for members that achieve their 
goals. It offers a range of goals appropriate to many sizes and types of businesses, 
relying on a network of partnerships with non-profits, local governments and trade 
associations to assist in recruiting and recognizing the over 3,000 members. Mem- 


139 






Chapter 4 - States and Tribes 


bers tripled their recycling rate in 1995, the first year of the program. It is the largest 
and fastest growing program of this type in the country. One participant, a medical 
supply manufacturer, recycled 105.3 tons of cardboard in 1994 and 1995, an increase 
of 300 percent. The company currently recycles an average of 15 tons of wastepaper 
a month. 

The Clean Industries 2000 program is a facility-based voluntary reduction program 
open to industrial facilities whose managers agree to reduce hazardous waste genera¬ 
tion and/or releases of pollutants into the environment by 50 percent by the year 
2000. Member facilities must also develop an internal environmental management 
program, sponsor one or more community environmental projects, and have envi¬ 
ronmental communication programs with their communities. Currently, there are 
163 members located throughout the state. Clean Industries members have achieved 
reduction in TRI releases from 1987 to 1994 of 29 percent, representing a decrease in 
toxics of 60 million pounds or approximately 408,000 pounds per facility. Between 
1992 and 1994, members reduced the generation of hazardous waste by 15.3 million 
tons. They sponsor 515 community environmental projects and participate in 152 
citizen communication programs. One member facility, Phillips 66 Borger Complex, a 
petroleum refinery, was one of the first participants in the Flexible Permit Program. 
The flexible permit replaced multiple air emissions permits with asingle permit which 
sets maximum allowable emissions but lets facility managers decide how to meet 
requirements. Emissions will decrease over 10 years for a total reduction of 13,000 
tons (40 percent) by 2005. 

Two of EPA’s regions have launched awards programs that consider applicants across 
a number of states. Region X’s Evergreen Award Program honors environmental 
leaders in the business community who promote a cleaner and safer environment and 
save operating costs at the same time. Region IX’s Green Business Recognition Pro¬ 
gram utilizes a multimedia checklist to reward businesses as diverse as auto repair 
shops and wineries that have strong compliance and pollution prevention records. 

State Program Activities 

Technical Assistance, Outreach, and Education 

Technical assistance activities include opportunity assessments, information clearing¬ 
houses, facility planning, hotlines, computer searches, and research projects. Out¬ 
reach and education activities include workshops, seminars, training, publications, 
and grants and loans. Table 4-3 summarizes these activities. 

Opportunity Assessments 

At least 40 state programs offer confidential, onsite pollution and waste assessments 
for small (and sometimes larger) businesses. The assessments generally take place 
outside of the regulatory environment and on a voluntary basis, thereby providing 
businesses with information on how to save money, increase efficiency, and proinote 


140 




Chapter 4 - States and Tribes 


Table 4-3. Pollution Prevention Activities in the States 7 


Technical Assistance Activities Outreach and Education Activities 


Opportunity 
State Assessment 

Clearing 

-houses 

Facility 

Planning 

Hotlines 

Computer 

Searches 

Research 

Workshops/ 

Seminars/ Publications 
Training 

Grants 
and Loans 

AL 

✓ 


✓ 


✓ 

✓ 

✓ 



AK 

AZ 

✓ 




✓ 


✓ 

✓ 


AR 

✓ 


✓ 







CA 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 


✓ 

CO 

✓ 


✓ 




✓ 

✓ 

✓ 

CT 

✓ 

✓ 


✓ 

✓ 


✓ 

✓ 

✓ 

DE 

✓ 




✓ 


✓ 



FL 

✓ 

✓ 

✓ 

✓ 



✓ 

✓ 


GA 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 


HI 






✓ 

✓ 

✓ 


ID 





✓ 


✓ 



IL 

✓ 

✓ 

✓ 

✓ 


✓ 

✓ 

✓ 

✓ 

IN 

✓ 

✓ 

✓ 


✓ 

✓ 

✓ 

✓ 

✓ 

IA 

✓ 


✓ 


✓ 

✓ 

✓ 

✓ 

✓ 

KS 

✓ 


✓ 

✓ 



✓ 

✓ 


KY 

✓ 


✓ 


✓ 

✓ 

✓ 



LA 

✓ 


✓ 


✓ 


✓ 



ME 

✓ 


✓ 


✓ 

✓ 

✓ 


✓ 

MD 



✓ 




✓ 



MA 





✓ 

✓ 

✓ 

✓ 

✓ 

MI 

✓ 



✓ 


✓ 

✓ 

✓ 


MN 

✓ 


✓ 

✓ 


✓ 

✓ 

✓ 

✓ 

MS 

MO 







✓ 




7 Source: National Pollution Prevention Roundtable, The Pollution Prevention Yellow Pages (September 1995). This table presents a snapshot of 
state P2 activities; however, given the dynamic nature of these activities, there may be more recent changes not reflected here. 


141 








Chapter 4 - States and Tribes 



Table 4-3. Pollution Prevention Activities in the States (Cont'd) 


Technical Assistance Activities Outreach and Education Activities 


Opportunity 
State Assessment 

Clearing 

•houses 

Facility 

Planning 

Hotlines 

Computer 

Searches 

Research 

Workshops/ 

Seminars/ 

Training 

Publications 

Grants 
and Loans 

MT 

✓ 




✓ 

✓ 

✓ 


✓ 

NE 

✓ 


✓ 




✓ 



NV 

✓ 



✓ 


✓ 

✓ 

✓ 


NH 

✓ 


✓ 


✓ 

✓ 

✓ 

✓ 

✓ 

NJ 

✓ 


✓ 


✓ 

✓ 

✓ 



NM 





✓ 

✓ 

✓ 



NY 

✓ 


✓ 


✓ 


✓ 


✓ 

NC 

✓ 


✓ 


✓ 

✓ 

✓ 


✓ 

ND 

✓ 


✓ 


✓ 

✓ 

✓ 

✓ 


OH 

✓ 


✓ 


✓ 


✓ 


✓ 

OK 

✓ 






✓ 



OR 

✓ 


✓ 


✓ 

✓ 

✓ 



PA 

✓ 


✓ 


✓ 

✓ 

✓ 


✓ 

RI 

✓ 


✓ 


✓ 

✓ 

✓ 


✓ 

SC 

✓ 


✓ 


✓ 

✓ 

✓ 

✓ 


SD 

TN 

✓ 


✓ 


✓ 

✓ 

✓ 


✓ 

TX 

✓ 


✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

UT 


✓ 




✓ 

✓ 

✓ 

✓ 

VT 

✓ 


✓ 


✓ 


✓ 


✓ 

VA 

✓ 




✓ 


✓ 



WA 

✓ 


✓ 


✓ 

✓ 

✓ 

✓ 

✓ 

WV 

✓ 


✓ 







WI 

✓ 

✓ 

✓ 


✓ 

✓ 

✓ 

✓ 

✓ 

WY 

✓ 


✓ 




✓ 




142 















Chapter 4 - States and Tribes 



a good public image. Waste assessment engineers review all operations of a business 
to identify potential waste reduction strategies and opportunities. Later, companies 
receive a detailed report that evaluates waste reduction opportunities and provides 
specific recommendations for action. The decision of whether to implement any 
recommended option is left entirely to the company. 

Many states employ retired engineers and graduate students to conduct assessments. 
The retired engineers enhance the credibility of state programs with industry. In¬ 
volving graduate students in the process helps the students to learn the pollution 
prevention approaches and encourages them to employ it in their careers. 

By informing businesses about more efficient production technologies and encourag¬ 
ing them to use pollution prevention equipment to proactively avoid compliance costs, 
state pollution prevention programs have helped industry recognize the economic 
benefits of source reduction. In some cases, state programs achieved substantial cost 
savings for businesses. For example: 

■ Businesses that received assistance from Kentucky Partners saved approxi¬ 
mately $3 million annually by implementing pollution prevention measures. 8 

■ Florida’s Waste Reduction Assistance Program (WRAP) has saved businesses 
$3.7 million. 9 

■ Companies receiving technical assistance from Alabama’s Waste Reduction and 
Technology Transfer (WRATT) program saved $160,000 on average. 10 

■ Iowa Waste Reduction Assistance Program (WRAP) has helped businesses in 
Iowa save more than $1.5 million annually. * 11 

■ Facilities that received assistance from Texas’ Permanent Pollution Prevention 
Program and Site Assessment Visit Programs are saving over 30 million 
dollars annually; have reduced hazardous wastes generations by 34,000 tons, 
non-hazardous wastes generation by 52,600 tons, and VOC emissions by 
179,000 pounds; and have conserved over 300 million gallons of water and 11 
million kilowatt hours of electricity by implementing pollution prevention 
projects in their facilities. 12 

In terms of environmental benefits, such as pollution avoided or waste reduced, some 
state programs have been able to measure significant results attributable to technical 
assistance activities. Sample benefits include: 

8 Kentucky Partners. Fact Sheet (January 1994). 

9 EPA. Pollution Prevention Incentives for States (Spring 1994). 

10 Alabama Department of Environmental Management. Alabama Pollution Prevention Program 
Final Progress Report (1994). 

11 Iowa Department of Natural Resources. Pollution Prevention Works for Iowa: Case Studies (April 
1993). 

12 Texas Natural Resource Conservation Comission. Pollution Prevention and Recycling in Texas: 

Report to the 75th Legislature (March 1997). 


143 






Chapter 4 - States and Tribes 


■ Tennessee showed a decrease in toxic releases of about 42 percent. 13 

■ West Virginia experienced a 53 percent decrease in toxic releases. 14 

■ Rhode Island’s program reduced 3.4 million pounds of liquid waste and 20,000 
pounds of solid waste. 15 

Information Clearinghouses 

According to EPA’s Pollution Prevention Information Tracking System data, over 30 
states operate information clearinghouses. In essence, a clearinghouse is a compila¬ 
tion of pollution prevention documents that can be accessed by state regulatory staff, 
targeted audiences, and the general public. These information centers generally pro¬ 
vide technical information on request. 

For example, the Virginia Department of Environmental Quality maintains an exten¬ 
sive library of pollution prevention materials. This clearinghouse contains more than 
3,000 books, articles, papers, and videos that cover all aspects of pollution prevention. 
The program makes its materials available for use by other organizations and is plan¬ 
ning to put the information clearinghouse index online so that the library will be acces¬ 
sible to other department staff and the general public for searching and requesting 
information. 

Facility Planning Assistance 

Over twenty states administer some kind of facility pollution prevention planning pro¬ 
gram. These programs are designed to encourage facilities that generate pollution to 
evaluate their processes with an eye toward eliminating waste and pollution. Although 
there is a substantial variation among the approaches taken by individual states, the 
planning programs have a core of common elements, including: 

■ Scope of Coverage. Planning requirements apply to facilities already subject 
to regulations, generally hazardous waste generators under RCRA or facilities 
subject to TRI reporting under EPCRA Section 313. Some states limit the 
planning requirements to larger businesses (RCRA large quantity generators), 
while others require planning from smaller entities (RCRA small quantity 
generators) as well. 

■ Wastes and Chemicals Addressed. Facility planning laws generally address 
toxic chemicals, as listed under EPCRA Section 313, or hazardous wastes, as 
defined under RCRA or state hazardous waste laws. However, plans may go 


13 Personal communication with George Smelcer, University of Tennessee Center for Industrial Services 
(May 1995). 

14 National Institute for Chemical Studies. West Virginia Scorecard ( 1992). 

15 Rhode Island Department of Environmental Management. Pollution Prevention in Rhode Island: 
Final Report on DEM's Pollution Prevention Program (June 1994). 


144 





Chapter 4 - States and Tribes 


beyond the scope of particular lists of substances or wastes to encourage 
prevention and to discourage waste shifting across environmental media. 

■ Focus of Planning. While all of the planning processes emphasize pollution 
prevention, some focus specifically on reducing the use of toxic or hazardous 
substances or reducing the generation of waste and pollution. Some programs 
emphasize recycling as well as prevention. 

■ Key Plan Elements. Plan elements generally include: assessment of existing 
processes that use or generate toxic chemicals or hazardous substances or 
wastes; technical and economic evaluation of the feasibility of reduction 
options; identification of options to be implemented; and establishment of 
numeric or other specific performance goals. 

■ Confidentiality and Public Availability. The planning process may preserve 
the confidentiality of some documents. Plans, or the assessments that underlie 
the plans, are often kept confidential, whereas plan summaries, annual reports, 
or planning goals are more often made public. Plans are generally available at 
the site to state officials. 

■ Statement of Corporate and Facility Management. Plans generally require 
a statement from corporate or facility management. Key elements of the 
statement relate to the accuracy and completeness of the plan and a commit¬ 
ment to implement the plan. 

■ Plan Summaries and Progress Reports. Plan summaries and progress 
reports are generally provided to the state agencies and made available to the 
public. The summaries and reports might include numeric goals, information 
on wastes generated and released,and schedules and progress made towards 
attaining plan objectives. 

■ Technical Assistance. States are generally authorized to run technical assis¬ 
tance programs to aid companies, particularly small businesses, in plan develop¬ 
ment and other related activities. 

■ Compliance, Enforcement and Requirements for Implementation. States 
may have the authority to enforce compliance with the requirement to submit 
plans or reports. However, they generally do not have the authority to enforce 
compliance with the plans themselves, unless the plans are implemented 
through some other vehicle, like a permit. The private recognition of waste and 
inefficiency, coupled with public awareness of releases into the environment, 
may be an incentive for industry to implement the plans. Some states have 
eschewed the use of their enforcement authorities and have chosen to implement 
their programs in a non-regulatory fashion. 

■ Assessment of Progress. Several state programs have provisions for assessing 
progress in particular sectors or user segments. Some states are authorized to 


145 







4 - States and Tribes 


disseminate information about successful approaches, while others can set 
performance standards for particular segments. 

Some state programs include additional planning elements, such as materials use 
data analysis and reporting, the indexing of wastes or pollution to levels of produc¬ 
tion, and mandatory employee training. 

Many of these programs have been in operation since the early 1990s, and several 
states have evaluated their progress. The National Pollution Prevention Roundtable’s 
Facility Planning Group recently reviewed a number of these state program evalua¬ 
tions. The review, which looked at evaluations from Massachusetts, Minnesota, New 
Jersey, Oregon, Texas, California, and Washington, concluded that a majority of the 
programs found pollution prevention planning processes and programs to be: 

■ effective in identifying pollution prevention opportunities, 

■ effective in facilitating improved environmental management, 

■ associated with a reduction in waste generated, 

■ associated with cost benefits, and 

■ associated with expected future benefits. 

The review also identified emerging issues in facility planning, including: 

■ more effectively integrating planning, and environmental issues in general, into 
overallbusiness management; 

■ improving cost accounting so that pollution prevention projects can compete 
better for capital; 

■ substituting environmental management systems, such as ISO 14000, for state- 
required pollution prevention plans; and 

■ targeting appropriate facilities, i.e., determining what size facilities are most 
likely to benefit from planning. 

Hotlines 

Some states operate a telephone assistance service to provide technical pollution 
prevention information to industry and the general public. Hotline staff answer spe¬ 
cific questions, provide referrals, and distribute printed technical materials upon re¬ 
quest. 

California, Connecticut, Michigan, and Pennsylvania are just a few of the states that 
operate pollution prevention hotlines. In Pennsylvania, the Center for Hazardous 
Materials Research (CHMR) provides small and medium-sized businesses with tech¬ 
nical assistance via a toll-free hotline. CHMR’s hotline also serves as a conduit for 
distribution of industry-specific fact sheets that provide targeted information on in¬ 
dustries, such as chemical production, coal mining, petroleum refining, and paper 
manufacturing. 




Chapter 4 - States and Tribes 


Computer Searches 

Some states perform computer searches to provide industry with up-to-date informa¬ 
tion about specific pollution prevention topics. Online capabilities allow pollution 
prevention programs to target their research efforts and address the particular needs 
of their clients. By searching the wide range of resources available electronically, 
states can provide industry with information about innovative pollution-reducing 
technologies, efficient indus¬ 
trial processes, current state 
and federal regulations, and 
many other pertinent topics. 

Over half the states provide 
this service. 

Research and 
Collaborative Projects 

State pollution prevention 
programs frequently partici¬ 
pate in research and collabo¬ 
rative projects with industry 
to foster the development of 
pollution prevention tech¬ 
nologies and management 
strategies. Research activi¬ 
ties can include a range of 
studies and surveys, database 
development, or data collec¬ 
tion and analysis. State pro¬ 
grams perform research both 
in the laboratory and in the field. 

Workshops, Seminars, and Training 

Almost all state pollution prevention programs conduct workshops, seminars, and 
technical training for industry, government, and student groups. Some programs 
train state and local environmental officials to focus on pollution prevention oppor¬ 
tunities as they carry out program office responsibilities. Other states emphasize 
training of pollution prevention staff to ensure a high level of expertise in the program. 

For example, the Tennessee Waste Reduction Assistance Program (WRAP) has de¬ 
veloped and delivered numerous presentations on waste reduction. Through 1994, 
WRAP has trained over 12,000 people. In response to the growing interest of Ten¬ 
nessee companies in solving their solid waste programs, WRAP has combined waste 
assessments and training efforts in Solid Waste Focus Groups. This program, in 
coordination with the Chamber of Commerce, trains industries to conduct snapshot 
assessments of their solid waste. 


Textile Research in Rhode Island 

The Rhode Island Department of Environmental Management conducted research 

on pollution prevention in the state’s textile industry. Activities included: 

■ Researching and identifying regulatory and policy initiatives that would 
encourage textile companies to incorporate source reduction measures and 
technologies into their process and facility operations. 

■ Identifying textile plants that represent the greatest potential risk to health 
and the environment through a comprehensive statewide survey, analysis of 
chemical release and offsite transfer data, and a review of the regulatory 
history of facilities. 

■ Researching, identifying, and evaluating cost-effective management and 
process operational methods, material substitutions, and technologies that 
could be used to reduce air/water releases and offsite transfers in facilities 
that represent the highest potential environmental risk. 

■ Analyzing textile industry discharges for toxicity. 

This research will expand the knowledge base and technical resources available to 

Rhode Island textile companies to reduce pollutants at the source. 


147 









Chapter 4 - States and Tribes 


Publications 

Publications allow state pollution prevention programs to target businesses and the 
general public. Numerous programs develop and distribute newsletters, fact sheets, 
and reports with pollution prevention information. 

Newsletters, for instance, are an effective way for state pollution prevention pro¬ 
grams to disseminate information to industry, other state programs and agencies, 
and other states. Typically, newsletters feature case studies of companies that have 
benefited from the efforts of the pollution prevention program, articles about perti¬ 
nent regulations and legislation, and notices of upcoming educational and outreach 
events. Many states’ newsletters have remarkably high circulations. For example, 
Kentucky Partners, a state pollution prevention center, has published over 27 issues of 
its newsletter, Waste-Line, and has distributed each issue to a mailing list of approxi¬ 
mately 7,000 people. 

Grants and Loans 

A number of states distribute funds to independent groups that conduct pollution 
prevention activities. Such support is generally used to fund research and to run 
demonstration and pilot projects. 

Arizona, for example, distributes Waste Reduction Assistance grants, which can be 
used to fund either source reduction or recycling projects for nonhazardous or haz¬ 
ardous waste. In recent years, most of the grants in this program have gone to indus¬ 
tries involved in enterprises such as aircraft building, heavy metals recovery, mining, 
and waste management. 

Regulatory Integration 

As discussed above, states are beginning to realize the importance of integrating the 
pollution prevention ethic into all areas of their environmental regulations. Some 
states have already begun to integrate pollution prevention into their regulatory ac¬ 
tivities; in other states, regulatory integration is only in the planning stages. Table 4-4 
summarizes the current status of states’ efforts to integrate pollution prevention into 
the following regulatory activities. 16 

■ Enforcement Settlements. States may use enforcement actions to encourage 
companies to initiate pollution prevention activities to come into compliance. 

In some cases, penalties may be lessened if a company institutes pollution 
prevention measures, such as a Supplemental Environmental Plan (SEP). 
Settlements involving multimedia pollution prevention requirements have 
occurred in some states. 

■ Permitting. States may require firms to develop pollution prevention plans as 
part of the permit application package. The issuance of facility-wide, multime- 


148 


16 The focus of this table is the integration of pollution prevention into regulatory operations: voluntary 
pollution prevention efforts are not included. 





Chapter 4 - States and Tribes 


Table 4-4. Regulatory Integration of Pollution Prevention 17 


State 

Enforcement Settlements 

Permitting 

Compliance Inspections 

Waste Management 

AL 




✓ 

AK 

✓ 

✓ 

✓ 

✓ 

AZ 

■ 

✓ 

✓ 

✓ 

AR 




✓ 

CA 

✓ 

✓ 

✓ 

✓ 

CO 

✓ 

✓ 

✓ 

✓ 

! CT 

✓ 

■ 


✓ 

DE 


✓ 

✓ 

✓ 

1 FL 

✓ 

✓ 

✓ 

✓ 

GA 

✓ 

✓ 

✓ 

✓ 

1 HI 



✓ 

✓ 

ID 


✓ 

✓ 

✓ 

IL 

✓ 

✓ 

✓ 

✓ 

IN 

✓ 


✓ 

✓ 

IA 


✓ 

✓ 

✓ 

KS 


■ 

✓ 

✓ 

KY 

✓ 


✓ 


LA 

■ 



✓ 

ME 




✓ 

MD 

✓ 



✓ 

MA 

✓ 

✓ 

✓ 

✓ 

MI 

✓ 

■ 

✓ 

✓ 

J MN 

✓ 

■ 

✓ 

✓ 

MS 




✓ 

MO 




✓ 

MT 




✓ 

NE 



✓ 

✓ 


17 Sources: EPA. Ongoing Efforts by State Regulatory Agencies to Integrate Pollution Prevention into Their Activities (September 1993); EPA. 
Update on State Source Reduction Activities (February 1996). [Note: The source reduction report includes some solid waste management 
practices not usually considered “pollution prevention,” e.g., recycling.] 


149 











Chapter 4 - States and Tribes 


Table 4-4. Regulatory Integration of Pollution Prevention (Cont'd) 


State 

Enforcement Settlements 

Permitting 

Compliance Inspections 

Waste Management 

NV 




✓ 

NH 



■ 

✓ 

NJ 

✓ 

✓ 

✓ 

✓ 

NM 




✓ 

NY 

✓ 

✓ 

✓ 

✓ 

NC 


✓ 

✓ 

✓ 

ND 

✓ 


✓ 

✓ 

OH 

✓ 

✓ 


✓ 

OK 


■ 

■ 


OR 


✓ 

✓ 

✓ 

PA 


✓ 

✓ 

✓ 

RI 

■ 



✓ 

SC 




✓ 

SD 

■ 

■ 

■ 

✓ 

TN 




✓ 

TX 

✓ 

✓ 

✓ 

✓ 

UT 

✓ 


■ 

✓ 

VT 

✓ 

■ 

✓ 

✓ 

VA 

✓ 

■ 

■ 

✓ 

WA 

✓ 

✓ 

✓ 

✓ 

WV 




✓ 

WI 

✓ 

✓ 

✓ 

✓ 

WY 

■ 

■ 

■ 

✓ 


✓ = regulatory integration underway; ■ = regulatory integration being planned/developed 


dia permits is an increasingly popular approach for incorporating pollution 
prevention into the permitting process. Such permits may reduce cross-media 
transfers and identify additional source reduction opportunities. 

■ Compliance Inspections. States may conduct facility-wide, multimedia 
compliance inspections. Such inspections provide a more comprehensive, in- 
depth assessment of facilities’ operations. Other types of pollution prevention 
activities include inspectors providing pollution prevention technology 
transfer and making referrals to state technical assistance programs. 


150 





Chapter 4 - States and Tribes 


■ Waste Management. Many states have laws that require pollution prevention 
measures to be used in the management of solid waste and hazardous waste. 
States may employ source reduction measures to fulfill these mandates. The 
development of RCRA waste minimization plans can also contribute to pollu¬ 
tion prevention efforts in the management of hazardous wastes. 

A number of states have used pilot projects to test new approaches for integrating 
i pollution prevention into their regulatory programs. Although such projects are usu¬ 
ally designed for unique state or local conditions, they emphasize the range of op¬ 
tions available to states. Pilot projects in Massachusetts, Ohio, New Jersey, Illinois 
and Indiana are discussed below. 

Case 1: Massachusetts 

The Massachusetts Department of Environmental Protection first piloted a multime¬ 
dia, pollution prevention-based inspection and enforcement program in 1986, known 
as the Blackstone Project. Based in part on the outstanding results of that project, 
Massachusetts has adopted a state-wide, prevention-based approach to compliance 
and enforcement called Waste Prevention F.I.R.S.T. (Facility-wide Inspections to Re¬ 
duce Sources of Toxics). In recent years, grant outputs for air, water, and waste were 
negotiated as a single compliance/enforcement package. The Region and state are 
i currently trying to develop and field-test a multimedia inspection protocol to meet 
media inspection requirements. Benefits of the project include: (1) promotion of 
pollution prevention through a whole-facility approach; (2) support for source reduc¬ 
tion as opposed to control solutions for compliance problems; (3) increased effi¬ 
ciency from a multimedia approach; (4) development of a clear definition of compli¬ 
ance roles in inspection protocol; and (5) inspection of more facilities. 

Case 2: Ohio 

Ohio’s EPA developed and implemented a statewide, multimedia pollution prevention 
strategy applicable to the entire state and involving all of the Agency’s divisions and 
programs. The Agency utilized RCRA grant funds from the Great Lakes Initiative to 
support these efforts. Under this program, the state also provided on-site pollution 
prevention for RCRA generators, developed a guidance manual for waste minimiza¬ 
tion planning for RCRA facilities, and prepared industry-specific pollution prevention 
fact sheets. Benefits have been: (1) initiation of pollution prevention activities under 
the RCRA grant, and (2) development of an overall long-term pollution prevention 
strategy for the state. 

Case 3: New Jersey 

New Jersey’s 1991 Pollution Prevention Act required the Department of Environmen¬ 
tal Protection to conduct a facility-wide pollution prevention pilot project. The project 
requires the state to issue facility-wide permits that meet the requirements of all the 
media programs, and to attempt to integrate pollution prevention planning into the 


151 







Chapter 4 - States and Tribes 


permit process. The Department has assisted facilities in developing pollution pre¬ 
vention plans and facility-wide permit applications. 


Case 4: Illinois 


The Illinois EPA integrated pollution prevention concepts into its permit decisions, 
compliance agreements, and regulatory actions across all the media programs. The 
state produced a pollution prevention guidance manual for use by Agency permit and 
inspection staff in all bureaus. The manual currently contains instruction materials, 
but will continue to evolve as successful pollution prevention projects are implemented 
and are documented. Illinois also drafted a guidance document, based upon federal 
EPA guidance, for incorporation of pollution prevention and Supplemental Environ¬ 
mental Projects into enforcement settlements. Additionally, Illinois has launched a 
voluntary technical assistance program for industry, whereby participating companies 
work with the Agency on pollution prevention initiatives. In return, the Agency pro¬ 
vides technical and regulatory assistance, including expediting permits, variance sup¬ 
port, and adjusted standard support. 


Case 5: Indiana 


In many tribal 
communities, basic 
environmental 
programs are still 
in the initial stages, 
and most tribes lag 
behind the states 
in pollution 
prevention 
infrastructure. 


Indiana’s Department of Environmental Management (IDEM) recognizes that suc¬ 
cessful integration of prevention into regulation is critical. IDEM’s pollution preven¬ 
tion program staff routinely prepare Pollution Prevention Impact Analyses on draft 
and proposed environmental rules published in the Indiana Register. These reports 
identify obstacles to pollution prevention and opportunities to promote pollution pre¬ 
vention, such as multimedia approaches to compliance and permitting. Several rules 
have been modified based on pollution prevention concerns identified in these analy¬ 
ses. 


Pollution Prevention On Tribal Lands 


Prior to 1992, essentially no pollution prevention activities were under way on tribal 
lands. In 1992, the All Indian Pueblo Council in New Mexico became the first tribe to 
receive PPIS grant monies. Since then, 18 PPIS grants and 14 Environmental Justice 
grants have been awarded to tribes. Nevertheless, in many tribal communities today, 
even basic environmental programs are still in the initial stages, and many maintain a 
single media focus rather than a multimedia perspective. 

Development of Tribal Pollution Prevention Programs 

As with the states, environmental concerns and approaches to pollution prevention 
vary from tribe to tribe. Federal grant programs, such as PPIS, have provided tribes 
with the flexibility to begin addressing the most salient pollution issues on reserva¬ 
tions. For example, Alaskan Native communities Chugachmiut and Kwethluk have 
focused their efforts on preventing pollution of local water resources, while tribes with 


152 





Chapter 4 - States and Tribes 


an agricultural base, such as the Poarch Creek Indians of Alabama, have concen¬ 
trated on developing pollution prevention strategies for agriculture. 

Barriers to Pollution Prevention 

Many tribes are located in rural, isolated areas where issues such as poverty and unem¬ 
ployment take priority over environmental concerns. Tribes rarely have sufficient 
resources—financial or professional—to devote to nascent environmental programs. 
As a result, many tribes are just now establishing basic infrastructure to address the 
most fundamental environmental problems. Promoting pollution prevention, which 
in this context is a more innovative and less tangible concept, presents a significant 
challenge. 

Some tribes have agreed to allow states to exercise jurisdiction over the environmental 
affairs of the tribe. In these cases, tribes do not focus on developing their own envi¬ 
ronmental programs; but rather, they rely on state programs to provide environmental 
assistance. This arrangement can hinder the development of pollution prevention ac¬ 
tivities on tribal lands, as many states channel their PPIS and other pollution preven¬ 
tion funds to industrial sectors and do not pass resources along to tribes. 

Another factor that has impeded the development of pollution prevention initiatives in 
tribal communities is a lack of communication between the tribes. Many tribal pollu¬ 
tion prevention projects are local in nature and do not focus on developing a commu¬ 
nication link to other tribes. As a result, few opportunities exist for the different tribes 
to develop a network for exchanging pollution prevention ideas. 

Solutions 

To help the Native American community further develop pollution prevention activi¬ 
ties, EPA, state pollution prevention programs, and tribal leaders have been working 
together to build networks among the tribes. These networks should help tribes find 
resources from other pollution prevention providers. At the first National Tribal Pol¬ 
lution Prevention Conference in August 1995,62 tribes from 28 states met in Montana 
to discuss pollution prevention issues, principles, and methods. Several tribal organi¬ 
zations, including the National Tribal Environmental Council (NTEC) and the Inter- 
Tribal Council on the Environment (ITCE), have taken an active role in promoting 
information sharing among the tribes. 

Tribal leaders and EPA realize that this early stage in the development of tribal pollu¬ 
tion prevention activity is crucial. Pollution prevention as an environmental tool is 
still a novel idea to many tribes. Many tribal leaders are promoting pollution preven¬ 
tion as a cultural value necessary to make progress on reservations as well as a concept 
essential to protecting the environment. 


For some tribes, 
whose traditional 
beliefs are rooted 
in respect for 
nature and 
sustainable 
development 
concepts, the 
pollution 
prevention 
message is easily 
adopted. 


Tribal Approaches to Pollution Prevention 

A few tribes have taken a broad approach to pollution prevention program develop¬ 
ment, focusing on building program infrastructure rather than implementing spe- 


153 





Chapter 4 - States and Tribes 


cific projects. The efforts of these tribes closely resemble the pollution prevention 
activities conducted by the states. AIPC, consisting of 19 pueblos of New Mexico, 
used its 1992 PPIS grant to initiate a pollution prevention program. Key elements of 
AIPC’s program include: 

■ Development of institutional structures within the 19 pueblos’ governmental 
entities to ensure that pollution prevention is incorporated into decision-making 
and planning. 

■ Creation of incentives and elimination of barriers to pollution prevention. 

■ Development of a multimedia pollution prevention effort that works in coordi¬ 
nation with state and federal programs. 

■ Development of a technical clearinghouse to provide educational and technical 
information. 

■ Collection, dissemination, and analysis of data to evaluate pollution prevention 
progress. 

In 1993, AIPC received a second PPIS grant that was used to create a pollution pre¬ 
vention resource guide for the 19 pueblos as well as other Indian tribes in the region. 
The Navajo Environmental Protection Agency initiated a similar pollution prevention 
program in 1993. 

Several tribes have focused their pollution prevention efforts on community education 
and outreach. To convince tribal governments to adopt pollution prevention policies 
and to raise cultural awareness of prevention concepts, tribal PPIS grantees have con¬ 
ducted workshops, developed curricula, and sponsored training sessions. The 
Passamaquoddy Tribe, for example, used its PPIS grant to provide informational bro¬ 
chures and cable TV broadcasts to the tribal community on water conservation, energy 
efficiency, and solid waste reduction. 

Most tribes that receive EPA pollution prevention funding concentrate their efforts on 
activities aimed at a particular area of need within their community. For example, to 
address the problem of poor air quality on and near their reservation, the Port Gamble 
S’Klallam Tribe replaced several noncertified wood-burning stoves with new stoves 
and conducted an in-home training program to teach community members about the 
negative effects of wood burning on air quality. 

Future Directions in Tribal Pollution Prevention 

As tribal environmental programs develop and Native American environmental man¬ 
agers move beyond the most immediate environmental problems on their reserva¬ 
tions, pollution prevention ideas and programs will become further integrated into 
tribal programs. Tribes have already benefited from the resources EPA provides in 
terms of pollution prevention technical assistance, and will continue to do so. Since 
1992, more tribes are applying for—and receiving—PPIS grants. As tribal pollution 
prevention programs develop and environmental managers gain experience in grant 


154 



Chapter 4 - States and Tribes 


proposal writing, federal and other (state/private foundation) resources will become 
more accessible to them. 

Tribal environmental leaders, as well as EPA and many state agencies, are now be¬ 
ginning to improve communication about environmental issues between the tribes. 
Tribal environmental managers hope to incorporate more pollution prevention top¬ 
ics into existing meetings, such as the biannual tribal environmental conference hosted 
by EPA and new forums like the 1995 conference in Montana. In addition, leaders are 
encouraging increased Native American participation in the National Pollution Pre¬ 
vention Roundtable as a means to further networking and technical information ex¬ 
change. 

The efforts of tribal environmental leaders to educate the Native American community 
about pollution prevention has, in many areas, already laid the foundation for the cul¬ 
tural and attitudinal shifts necessary for adoption of the pollution prevention ethic. As 
education and outreach efforts continue, tribal awareness and acceptance of pollution 
prevention will continue to grow. 

Future Directions and Conclusions 

This chapter has demonstrated how state and tribal programs have evolved since 
1991. Many states have expanded their programs and moved from policy develop¬ 
ment to implementation. Native American communities have established a basis for 
further development of pollution prevention efforts. As they continue to develop, 
state programs face continuing challenges as they build on early successes in creat¬ 
ing technical assistance programs and incorporating prevention into regulations. 

■ Follow up. The first challenge facing state programs is is to determine 
whether companies that receive state services are actually implementing 
pollution prevention activities as a result of the services. Even if a direct link 
cannot be made in all cases, states may be able to get a better feel for whether 
their message is getting through. A major barrier to collecting this informa¬ 
tion in the past has been limited resources. EPA has already begun to offer 
grants to the states to fund follow up research and measure success. Once state 
programs can identify facilities that are implementing pollution prevention, they 
can more easily measure the general effectiveness of their technical assistance 
recommendations and program services. To maintain future funding at both the 
state and federal level, it is imperative that states demonstrate the effectiveness 
of their programs. 

■ Regulatory integration. Most environmental protection is implemented 
through state media programs. In order for pollution prevention to take hold, 
state media programs need to see how prevention can help achieve their goals. 
Prevention is important for regulatory programs because single media pro¬ 
grams may have the effect of shifting waste across environmental media. The 
single media regulatory structure is not conducive to understanding these 


In order for 
pollution 

prevention to take 
hold, state media 
programs need to 
see how prevention 
can help achieve 
their goals. 


155 




Chapter 4 - States and Tribes 


cross-media issues, or acting on them. Due to the difficulty in changing 
organizational biases and the time required to develop a pollution prevention 
mentality among state regulatory and compliance staff, states will continue to 
struggle with this issue over the near term. 

■ Optimize pollution prevention funding. States face continued challenges in 
expanding or even maintaining funding for prevention programs, in the face 
of continued pressure for budget cutting, and a changing framework for 
federal-state relationships. Despite demonstrated economic and environmen¬ 
tal benefits, established technical assistance programs in some states are under 
threat of reduction or elimination by state legislatures. If states relinquish a 
regulatory responsibility in an environmental program, it is likely that the 
federal government will take over that responsibility. There is no analogous 
authority for an increased federal presence in non-regulatory pollution 
prevention technical assistance programs. Federal funds cannot fill the gap. 

The Pollution Prevention Act requires states to match any federal funds 
provided in grants under the Act. 

P2 technical assistance programs face a major challenge in piecing together a 
stable level of funding from a variety of sources, and maintaining political 
support for these programs. States will lose expertise and momentum for 
prevention if these programs are cut, even if they are reconstituted in a similar 
form elsewhere. 

The National Environmental Performance Partnership System and the Perfor¬ 
mance Partnership grants can provide additional flexibility for states to develop 
and pursue their own environmental objectives. These changes in federal-state 
relationships might give states the ability to shift resources to multi-media 
approaches, or to integrate prevention into regulation. They may also make it 
easier for states to shift resources out of prevention. 

Tribal programs face the following challenges in the coming years: 

■ Environmental program development. As tribal environmental programs 
mature and Native American environmental managers begin moving beyond 
addressing the basic environmental problems on their reservations, pollution 
prevention ideas and programs will become further integrated into tribal 
programs. Tribes have already benefited from the resources EPA provides for 
pollution prevention technical assistance, and will continue to do so. 

■ Communication barriers. A lack of communication between the tribes has 
impeded the development of pollution prevention in tribal communities. To 
help the Native American community further develop pollution prevention 
activities, EPA, state pollution prevention programs, and tribal leaders have 
been working together to build networks among the tribes. These networks 
should help direct tribes to resources from other pollution prevention providers 
and allow them to further develop their programs. 


156 






Chapter 4 - States and Tribes 


Pollution prevention education. The efforts of tribal environmental leaders 
to educate the Native American community about pollution prevention has, in 
many areas, already laid the foundation for the cultural and attitudinal shifts 
necessary for adoption of the pollution prevention ethic. Tribal communities 
are beginning to recognize pollution prevention as a value necessary to make 
progress and as a way to save money and resources. As education and 
outreach efforts continue, tribal awareness and acceptance of pollution 
prevention will continue to grow. 


157 






Chapter 4 - Guest Commentary 


Promoting Pollution Prevention: The North 
Carolina Perspective 

by 

Linda Bray Rimer 

Assistant Secretary for Environment Protection 
State of North Carolina 

Department of Environment, Health and Natural Resources 
Raleigh, North Carolina 

The role of the states in promoting pollution prevention has changed over the last five years. Five years ago, states 
were looking to EPA for guidance in institutionalizing pollution prevention. While this is still true today for some 
states, many other states have taken the lead in making pollution prevention an integral part of environmental 
management. This is important in that pollution prevention has moved beyond “special projects,” to being incor¬ 
porated into rule making, policy development, and even job descriptions. 

It has never ceased to amaze me that what seems so obvious — that prevention of pollution is superior to the 
control or remediation of pollution — is apparently not that obvious to a large proportion of both the environ¬ 
mental regulators and the folks they regulate. 

My “answer” to what states can do to promote pollution prevention is to try and ensure that the pollution 
prevention staff participates in all substantive policy discussions, i.e., that we always have a “pollution preven¬ 
tion voice” at the table. As an example, North Carolina has been consumed for the past year with environmental 
concerns related to animal waste and other non-point source pollution related to agricultural practices. While 
everyone was patting themselves on the back about a new requirement to provide buffers along stream segments, 
the pollution prevention staff reminded us that this was merely an “end-of-pipe” technique with the buffers 
controlling the pollution. The key to true water quality protection was in preventing the pollution from getting 
to the buffers with practices such as nutrient management. 

Beyond these specifics, a broader and very important activity for states to engage in must be the development of 
appropriate outcome measures or identification of environmental indicators of environmental protection prac¬ 
tices. If we are measuring the right parameters, then prevention will become the obvious and best way to achieve 
the desired outcome. I believe one of our greatest problems is that we chose early on to define pollution preven¬ 
tion as an end unto itself rather than as a means to an end - which is better environmental protection and smart 
environmental management. 

The most difficult challenge state agencies must face in mainstreaming pollution prevention into their environ¬ 
mental programs is changing the culture of environmental protection and regulation! 

In 1990-1991, when it became evident that pollution prevention was not as intuitively obvious to environmental 
regulators as some anticipated, we began talking about the need for cultural change. This broader debate 
allowed us to place pollution prevention practices within a philosophical context so that we could analyze the 
way in which people do, or do not adapt to or embrace change. 

While this helped us understand better what was happening, it did not substantively accelerate the process. 
Change occurs slowly - as we have seen with pollution prevention and are seeing today with the new partner- 



158 







Chapter 4 - Guest Commentary 


ship system that is intended to redefine State - EPA relationships. But patience is a virtue and persistence eventu¬ 
ally pays off. Keeping the pollution prevention voice at the table, measuring the right outcomes, and taking 
advantage of industry’s gradual recognition that broader environmental management systems, such as the ISO 
14000 standards, make more sense for the corporate bottom line and for environmental protection, than do media- 
specific, one-pipe-at-a-time permit limits, have all contributed to our progress. 

One of the most promising, innovative pollution prevention programs about which I am most excited, is the 
growing appreciation and adoption of broad, environmental management systems, the most popular one being 
the ISO 14000 standards. We are finally realizing that, as environmental regulators, we must reach beyond our 
previous goal of having the regulated community in compliance with all its permits at a given time. A quick 
assessment of the Toxic Release Inventory showed us that this kind of regulatory system is not sufficiently 
protective of our environment. Rather, we should be educating ourselves about these systems and identifying 
incentives for industry to adopt them. 

In North Carolina, we are examining these systems and testing the theory that they do result in superior environ¬ 
mental performance and protection. I have challenged my staff to pursue four main questions: (1) What should 
the relationship be between a company that adopts these systems, or becomes certified to the standards, and an 
environmental regulatory agency? (2) How do we assist small- and medium-sized companies to adopt these 
systems? (3) What kind of environmental indicators should we be measuring to ensure that we are, in fact, enhanc¬ 
ing environmental protection? and (4) How do we keep the entire process transparent to the public and the appro¬ 
priate stakeholders involved? 

In response to a question about what makes this system work, I suggest that it is too early in the process and the 
jury is still out. Companies are adopting these systems because the outcomes support corporate goals - both 
economic and environmental. I believe that environmental regulators will soon begin to appreciate the results of 
these programs. It will not be sufficient, however, for environmental regulators to continue enforcing environ¬ 
mental rules in the same old way for companies that have truly moved beyond just compliance as a consequence 
of their environmental management system. We need to pursue new relationships between regulators and those 
they regulate, and among regulators, regulated groups, and the public. The need for cultural change continues! 


159 




Chapter 4 - Guest Commentary 


Preventing Pollution Through New 
Partnerships and Incentives 

by 

Mary A. Gade 

Director 

Illinois Environmental Protection Agency 
Springfield, Illinois 

Mary Gade is the immediate past president of the Environmental Council of the States. 

In the summer of 1995, the Illinois Environmental Protection Agency celebrated its twenty-fifth anniversary. Up 
until recently, much of our focus has been on using “command and control” approaches to curb the release of 
pollutants into the environment of our state. So far, we have had good results. The level of compliance for 
industrial facilities subject to air and water pollution regulations in Illinois now exceeds 90 percent. We are 
proud of what we have accomplished. 

In spite of these accomplishments, however, we are still experiencing ambient air quality problems in our 
larger urban areas, some of our lakes and streams do not meet the water quality standards, and too much waste 
is being generated and shipped off-site for treatment or disposal. Obviously, more work needs to be done to 
protect our air, water, and land. We know that we cannot rest on our laurels. 

At present, we do not expect to see the passage of new regulations mandating the use of more extensive add-on 
controls, and we do not necessarily want them. High costs, marginal returns, and limited resources make such 
traditional approaches unappealing. Instead, we believe the next generation of environmental improvement 
will likely be achieved through technological and continuous improvement programs that take place within 
facilities. Additional improvement also will result by using common sense approaches to bring more firms, 
particularly smaller ones, into the regulatory system. To be successful, these efforts will require a new way of 
doing business, involving better tools and communication skills. And one thing is certain — pollution preven¬ 
tion will be an integral part of this effort. 

In the last year, our state has initiated a number of compliance assistance programs for small businesses, includ¬ 
ing our “Clean Break” amnesty program, technical assistance hot line, and easy to understand guides on environ¬ 
mental regulations. The next step will be to provide more in-depth training to our inspectors and permit writers 
on regulatory assistance issues for small businesses. This training initiative will involve pollution prevention, 
including arming our staff with laptops and software aimed at providing information on sector-specific tech¬ 
niques and model facilities. We will be retooling our total quality management program to focus on these inno¬ 
vations, recognizing that we must improve our client awareness and listening skills so that we can communicate 
more effectively with the regulated community and others. 

We have embarked on a collaborative initiative with business groups and environmentalists, known as the Great 
Printers Project, to give special recognition to lithographic printers seeking to achieve compliance through pol¬ 
lution prevention. We believe this partnership will become a model for bringing together different interest 
groups and government to work cooperatively for environmental change. 

We want to find new messengers to promote pollution prevention, knowing that many business owners are 
distrustful of government bureaucrats and not likely to respond to conventional pollution prevention promo- 



160 



Chapter 4 - Guest Commentary 


tional campaigns. To this end, we are developing a pollution prevention curriculum for accountants and looking 
for ways to promote pollution prevention through attorneys, lenders and suppliers that are considered more reli¬ 
able sources of information, especially small businesses that do not have environmental staff or resources. 

Collaborating with community economic development groups also will be a priority for our agency. Pollution 
prevention is not only good for the environment but it can be powerful tool to foster industrial modernization 
and retention. By working with local technical assistance providers, we can help companies understand their 
environmental obligations, identify opportunities for regulatory reform and recommend pollution prevention mea¬ 
sures that may help them save money, improve efficiency, or reduce their regulatory requirements -- a plus for 
everybody. 

In the case of larger companies, we must create more incentives for them to go beyond compliance with existing 
environmental rules to developing environmental management systems that will take advantage of pollution 
prevention opportunities. To this end, Illinois is one of the first states in the country to pass legislation allowing 
industries and other regulated entities to pursue regulatory innovation or “XL” projects on a pilot basis. Through 
this initiative, we will be encouraging cooperating companies to achieve pollution reductions in excess of exist¬ 
ing regulatory requirements through systematic approaches that emphasize pollution prevention, stewardship, 
stakeholder participation, and other measures. 

The next several years will tell us whether a fundamental shift in environmental management, from “command 
and control” to more cooperative prevention-oriented strategies, will help us address our high priority environ¬ 
mental problems. It is going to take more than just a simple shift in priorities and resources. We must develop 
new types of partnerships, creative incentives, and improved forms of communication to make pollution preven¬ 
tion the absolute top priority for all of our environmental protection efforts. 


161 







Chapter 4 - Guest Commentary 


Pollution Prevention Innovators — State, Local 
and Tribal Governments 

by 

Andrea Farrell 

Chair of the Board of Directors 
National Pollution Prevention Roundtable 
Washington, DC 

State, local and tribal governments, the early pioneers of the pollution prevention movement, continue to play a key 
role in developing and promoting prevention-first approaches nationwide. However, times and roles have changed. 
Five years ago, state and local governments were still in the midst of experimenting with a number of different 
approaches and techniques. Today as a result of this experimentation, we have collected and analyzed much data 
on what has worked and what has not; we now have a track record. 

The challenge for today’s pollution prevention government practitioners is to go beyond the “low hanging fruit” 
and tackle the more difficult institutional changes that are necessary to make pollution prevention a central 
cornerstone of our nation’s environmental policy. 

To achieve this culture change, pollution prevention practitioners from federal, state, local and tribal govern¬ 
ments must be employed at upper management levels within their agencies and have input in all core policy 
discussions. In addition, the current statutory and regulatory framework that relies on traditional end-of-pipe 
environmental management approaches, such as control and treatment, must be modified to ensure that pollution 
prevention is a priority, not a peripheral program. 

Many new and innovative multi-stakeholder partnership programs are demonstrating the benefits of pollution 
prevention and helping it spread both nationally and globally. For examples the NPPR’s Materials Accounting 
Project, a collaborative effort between the NPPR and member companies of the Business Roundtable Industrial 
Pollution Prevention Council, is examining ways materials accounting can enhance the efficiency and environmen¬ 
tal performance of industrial facilities and whether chemical use reporting can meet the diverse needs of industry, 
government, and public interest shareholders. 

The Great Printer’s Project, another innovative multi-stakeholder program which includes representatives from the 
Environmental Defense Fund, Printing Industries of America, and the states of Illinois and Wisconsin, aims to 
provide small business in the printing industry with one-stop shopping for environmental management information. 

Internationally, the European Roundtable on Cleaner Production (ERCP) has succeeded in attracting representa¬ 
tives from all over Europe to its annual conferences. The NPPR is also working with the U.S.-Asia Environmental 
Partnership (US-AEP) to form roundtables in eight southeast Asian countries. Efforts to form roundtables are also 
underway in Africa, the Middle East, and South America. These organizations bring together government officials, 
members of industry, and non-governmental organizations. 

Lastly, the United Nations Environment Program (UNEP) is working with NPPR on a P2 Declaration that will 
change the course of environmental policy by committing heads of states to adopting a national environmental 
policy based on prevention approaches. These efforts demonstrate how the concept of preventing pollution 
(prevention first) is becoming ingrained in the minds of businesses, government agencies, and non-governmental 
organizations around the world. 



162 





Chapter Five 

Prevention at Educational 
Institutions: Engaging 
Future Leaders 


■ K-12 Programs 

■ University-level Programs 

■ Guest Comments: 

David Allen, The University of Texas 
at Austin 

Michael Heiman, Dickinson College 

Jonathan W. Bulkley, National 
Pollution Prevention Center at the 
University of Michigan 



Chapter 5 - Educational Institutions 




Chapter 5 - Educational Institutions 


Introduction 

Prevention programs can start as early as elementary school and extend into gradu¬ 
ate school programs. Educational institutions at all levels are making great strides 
in developing and incorporating pollution prevention programs. Students in grades 
K-12 are learning about pollution prevention through projects designed to foster 
environmental stewardship. At the college level, students are offered a growing 
number of courses in environmental studies. In addition, universities are beginning 
to develop a multidisciplinary approach to pollution prevention and conservation. 
Environmental concepts are being incorporated into a wide variety of courses from 
urban planning to economics. Students, faculty, and staff are active in developing 
and participating in campus pollution prevention programs and related research and 
development. Many colleges and universities have committed to a leadership role in 
pollution prevention. Faculty are using information technology to help identify and 
transfer pollution prevention information. The nation’s educational institutions are 
engaging in technical assistance programs and partnership programs with industry and 
government. 

The growth of pollution prevention programs in educational institutions has been 
helped by two laws passed in 1990 — the National Environmental Education Act 
and the Pollution Prevention Act. Both these acts helped build a framework for 
integrating pollution prevention into educational programs across the United 
States. 

The National Environmental Education Act of 1990 focused attention on the need 
for incorporating environmental awareness into the educational system from kin¬ 
dergarten through grade 12 and beyond. The Act also charged EPA with the re¬ 
sponsibility for coordinating federal environmental education initiatives at the 
national level. In response, EPA established an Environmental Education Divi¬ 
sion to advance and support national education efforts to develop an environ¬ 
mentally conscious and responsible public. Among the programs started are en¬ 
vironmental education grants, an environmental teacher-training program, the Na¬ 
tional Network for Environmental Management Studies Fellowship Program, and 
the Native American Scholarship Program. Congress also created a nonprofit or¬ 
ganization, the National Environmental Education, and Training Foundation to 
foster partnerships between the public and private sectors to fund and develop 
environmental education programs and initiatives. 

By recognizing source reduction as the nation’s preferred approach to environ¬ 
mental protection, the Pollution Prevention Act of 1990 has stimulated educators 
efforts to raise student awareness about source reduction. Under the Pollution 
Prevention Act, EPA has supported schools, universities, and nonprofit organiza¬ 
tions in developing innovative ways to incorporate pollution prevention ideas into 
educational initiatives. 

What is new in educational initiatives in pollution prevention is the emphasis on waste 
reduction rather than the traditional curriculum concentrating on natural resource con- 


Prevention 
programs can start 
as early as 
elementary school 
and extend into 
graduate school 
programs. 


165 





Chapter 5 - Educational Institutions 


servation and recycling. Source reduction and pollution prevention concepts encour¬ 
age students to think differently about pollution and their own roles in preventing 
environmental degradation. Students begin to appreciate the life cycle of products 
they use on a daily basis and consider the environmental implications of routine 
decisions they make. 

This chapter describes some of the most successful pollution prevention programs 
and activities in U.S. educational institutions. The chapter is organized into two 
sections: 

■ K-12 Programs 

■ University-level Programs, which include both internal activities (pollution 
prevention, curriculum development, faculty research and development, 
campus pollution prevention programs) and external programs (technical 
assistance programs, partnership programs, community and facility audits). A 
prevention training program targeted toward community college students is 
also described in this section. 


K -12 Programs 

In the 1970s, environmental education programs emphasized natural resources con¬ 
servation and environmental impacts. As neighborhood recycling programs became 
increasingly common in the late 1980s, educators began recycling in their classrooms 
as a way of involving students in activities that preserve the environment. In the early 
1990s, educators began integrating pollution prevention into the curriculum. This was 
accomplished with a diverse selection of increasingly sophisticated interactive tools, 
games, and activities to stimulate students’ appreciation and understanding of basic 
ecology and conservation principles. Drawing on these resources as a starting point, 
educators have taken pollution prevention to its logical conclusion by discussing 
source reduction as the best way to reduce the consumption of natural resources and 
minimize environmental impacts. 

In some cases, educators teach source reduction and recycling concepts in the con¬ 
text of a natural resource issue that hits home. For example, 105 fifth graders at Clark 
Elementary School in Spring, Texas are saving their city 575,000 gallons of ground 
water annually. Along with 55,000 other students in the upper Gulf Coast area, they 
are participants in a program called “Learning to Be Water Wise and Energy Efficient” 
created by the nonprofit educational group, the National Energy Foundation. The 
program combines classroom discussion, problem solving in math and science, and 
creative activities with “homework”— high efficiency plumbing fixtures, which are 
taken home, installed, and monitored. Implemented in the Harris-Galveston Coastal 
Subsidence District on a full-scale basis in the 1994-95 school year, the program is 
being sponsored by public water suppliers in partnership with local elementary and 
intermediate schools. 1 


166 


1 EPA, “Water-Wise Students Bring Home Savings” Pollution Prevention News (September/October 1995). 



Chapter 5 - Educational Institutions 


In May 1997, nineteen groups of students from around the country were honored with 
the 1995 and 1996 President’s Environmental Youth Awards. I 2 These awards recog¬ 
nize students who take a leadership role in learning about and protecting the environ¬ 
ment in their local communities. Among the winners was a group of high school 
students in Tulare, California that converted an unused portion of a school parking lot 
into a mini-park for the school and the community. Students in the Environmental 
Biology classes planned and completed the project over five years, and each class had 
a distinctive role, from concept development and initial planning to solicitation of 
materials, pavement removal, earth moving and landscaping. Presiding over the 
new park is a larger-than-life statue, commissioned by the students, of Chief Se¬ 
attle who is known for his words, “The earth does not belong to man. Man belongs 
to the earth.” 

A consortium of organizations is cooperating on a project to develop an environmental 
education program that targets middle/junior high school students in the State of New 

Necessary Wrapper? Activity 

Purpose: To help students realize that large amounts of packaging may be used to wrap products they buy. Some 

packaging is needed to protect the product, but how much is enough? 

Grade level: K through 3 

Focus: One out of every $11 is spent on product packaging in the United States. We have gotten into the habit of 

buying items for convenience, without thinking about how much or what we throw away. In this exercise, find 

out how much waste is from packaging. 

Procedure: 

1. Ask children to unwrap the product, saving all packaging. 

2. Weigh pile of packaging and pile of product. Which weighs more, the product or the packaging? 

3. Ask the children why there are so many wrappers and try to identify a use for each. How would the 
children package the product? 

4. Have the children identify the source of the raw materials for the packaging, i.e., the plastic, aluminum, 
paper. 

5. Ask the children to think of other things that their families buy that come in packages. 

Enrichment: 

■ Discuss if we reduce the amount of packaging, will we reduce the amount of garbage? What packaging is 
easily recycled, what is difficult to recycle? 

■ Discuss what everyone can do to help, such as buying items in bulk and then dividing it, buying easily 
recycled materials, letting stores know if there are overpackaged items such as vegetables, meats, or 
convenience foods. 

■ Write letters to companies that are overpackaging. 

Source: Composting in Schools produced by Cornell University Program in Environmental Sciences for Educators and Youth, 1997 

(www.cfe.cornell.edu/compost/schools.html) 


I 2 EPA Press Release “Nineteen Student Groups Honored with the President’s Environmental Youth 

Awards” (May 23, 1997). 


167 











Chapter 5 - Educational Institutions 


York. The program’s goal is to call attention to Great Lakes environmental issues. 
This public/private partnership brings together the support of Niagara Mohawk Power 
Corporation, National Audubon Society, Inc., and EPA, working with Earth Genera¬ 
tion, Inc., a private developer/facilitator of environmental education programs. 

Under the program, Earth Generation will develop 10 projects that center around the 
following four key issues: 

■ Achieving Air Quality 

■ Preserving Water Quality 

■ Living for the Ecosystem 

■ Caring for the Land 

Three of the four issues (1,2 and 4 above) specifically discuss pollution prevention 
as a problem solving approach. 3 Similar projects are already in use in Michigan and 
Arizona. 

E2 (Environment and Education) is a nonprofit organization that aims to provide fu¬ 
ture generations with environmental knowledge and tools necessary to make changes 
toward a sustainable future. This organization has developed an activity-based cur¬ 
riculum, Environmental ACTION , that teaches students how to prevent pollution in 
their school and home environments. The program targets students in middle schools 
and high schools to investigate human health, resource consumption, and environ¬ 
mental issues and practice taking actions for improvement. Environmental ACTION 
responds to needs for environmental education activities that emphasize personal 
responsibility and positive action to prepare students to participate actively in conserva¬ 
tion efforts. The curriculum consists of several modules, including the following: 

1 . Energy Uses & Conservation - students explore energy production, use, and 
environmental effects. Using the school as a research laboratory, students 
examine how to improve the energy efficiency of their schools and homes. 

2. Source Reduction & Waste Management - students sort and analyze their 
school’s garbage to identify recyclable and compostable materials. They 
formulate a plan to reduce their consumption and waste at school and home. 
The development or improvement of an existing recycling program is part of 
the process. 

3 . Water Quality & Conservation - after an introduction to water consumption 
and quality issues, students conduct an audit of water usage and efficiency on 
the school campus. Then they develop strategies for conserving water at 
school and home. 


168 


3 Earth Generation, Inc. As printed in EE-Link, the web site for the National Consortium for 
Environmental Education and Training. For further information, contact Earth Generation at 517-631- 
4010 (E-mail: EarthGen@aol.com). 



Chapter 5 - Educational Institutions 


4. Habitat & Diversity Enhancement 
- students investigate the types of 
toxic materials, chemical products, 
cleaning supplies, and pesticide 
practices used in their school, how 
they are stored and disposed of, 
and what their potential effects are 
on human health and the environ¬ 
ment. After evaluating the results, 
students develop a plan for using “earth and human-friendly” alternatives at 
school and home. 4 

Spurred by legislation at the federal, state, and local levels, the field of environmental 
education is rapidly expanding both in the United States and world-wide. Organiza¬ 
tions such as the EPA-funded Environmental Education and Training Partnership Project 
are accelerating the pace of environmental education through improved information 
transfer, basic training materials, and training for educators. Building on these and 
similar activities, and well-rooted curricula in ecology and resource conservation, edu¬ 
cators have begun interweaving prevention concepts into course materials and activi¬ 
ties. K-12 students are changing the way their schools and communities resolve envi¬ 
ronmental issues as a result of their hands-on experience and familiarity with pollution 
prevention. 

University-level Programs 

Nationwide, colleges and universities have begun to embrace pollution prevention as 
well. Universities play an important role not only in educating future leaders but 
also as centers for research and development for creating and exchanging new pollu¬ 
tion prevention technologies. Many centers go beyond engineering research and 
development and provide forums for regulators, businesses, and local communities 
to come together to resolve environmental issues through pollution prevention. Col¬ 
leges and universities have internalized pollution prevention and are making broad 
sweeping institutional changes to reduce environmental impacts and consumption of 
natural resources on their campuses. 

Pollution Prevention Curriculum Development 

In the 1970s, colleges and universities began establishing environmental science/ 
studies departments in order to meet the demand for trained environmental profes¬ 
sionals. However, course work in environmental science was often not integrated 
with other disciplines. 


The National Consortium for Environmental Education and Training 
has created a gopher and web site for environmental education called 
EE-Link (http:/eelink.umich.edu). EE-Link’s mission is to spread in¬ 
formation and ideas that will help educators explore the environment 
and investigate current issues with students. The target audience is 
teachers and others who support K-12 environmental education such 
as media specialists, in service providers, nature centers, and curricu¬ 
lum developers. 


4 Environmental Action modules will be published beginning in late fall 1996 through 1997 by 
Addison-Wesley Longman. For further information, contact E2 at 310-573-9608 (E-mail: 
e2@earthspirit.org). 

169 




Chapter 5 - Educational Institutions 


The work of incorporating pollution prevention ideas into the curricula of college- 
level courses has been taken up by profit organizations and a handful of individual 
instructors. Concepts of source reduction and recycling were initially integrated in the 
science and engineering departments but have since spread to business schools and 
even to liberal arts programs. Several well-known universities are in the forefront of 
this effort, including: the University of Michigan, the University of Massachusetts - 
Lowell, and the Florida Institute of Technology. 

The National Pollution Prevention Center (NPPC) at the University of Michigan of¬ 
fers many tools and strategies to incorporate pollution prevention concepts into the 
curricula of universities and colleges for faculty, students, and professionals. 5 The 
NPPC publishes Pollution Prevention Educational Resource Compendia in a variety 
of disciplines, including business law, chemical engineering, chemistry, accounting, 
industrial engineering/operation management, agriculture, architecture, and strategic 
management. Each compendium offers a discipline-specific resource list (which is 
available on the World Wide Web at http://www.UMich.edu/nppcpubResLists/), 

Case studies are a popular way of “greening” the curriculum of business schools. 

Many of the case studies being developed by Harvard Business School, WRI/MEB, 

NPPC, and other organizations are based on real-life examples of the intersection of 
environment and business. At the same time, they offer a richness of detail for 
students to ponder. Examples of WRI/MEB case studies include: 

■ A simulation exercise involving hydropower and salmon in the Columbia 
River Basin that illustrates the complex nature of sustainable development. 

■ A classic example, based on AT&T’s Columbus Works plant, of how total 
quality management techniques can be used to eliminate environmental 
hazard. 

■ A case study of Industrial Products, Inc. That examines managers’ efforts to 
design and implement a system for measuring the environmental impacts of 
its operations. 

ing in the internship program work directly with 
mentor who provides academic guidance for the work experience. 

The NPPC publishes a Directory of Pollution Prevention in Higher Education: Fac¬ 
ulty and Programs in order to help build a national network of pollution prevention 
educators who can contact each other to share information, ideas, and curricula. The 
first edition, published in 1992, contained 89 faculty members. The second edition, 
published two years later, contained 127 more entries bringing the total to 216 
faculty. 


an annotated bibliography, 
selected readings, syllabi, 
and assignments. Course 
compendia and other educa¬ 
tional materials being de¬ 
veloped by the NPPC are 
based on a systems ap¬ 
proach to pollution preven¬ 
tion. In addition, the NPPC 
offers a unique national in¬ 
ternship program that pro¬ 
vides practical experience 
to undergraduate and gradu¬ 
ate students in waste pre¬ 
vention process assess¬ 
ments. Students participat- 
an organization and a faculty 


170 


5 The National Pollution Prevention Center for Higher Education. Program brochure. Additional 
information on NPPC can be obtained via the web site: http://www.snre.umich.edu/nppc/ or by 
calling 313-764-1412. 



Chapter 5 - Educational Institutions 


A number of organizations are promoting environmental business education courses 
for undergraduates, graduate students, and business executives. Since 1990, the Man¬ 
agement Institute for Environment and Business (MEB) has worked with business 
schools to facilitate an understanding of environmental issues in MBA programs. For 
instance, the Business-Environmental Learning and Leadership Program (BELL) is a 
consortium of 25 business schools working with MEB to assemble environmental 
courses on their campuses. 6 The BELL Best Management Practices course centers on 
environmental management techniques used by leading companies, such as environ¬ 
mental accounting, design for environment, pollution prevention, life-cycle analysis, 
and quality management. 

In October 1996, MEB merged with the World Resources Institute (WRI), a center 
for policy research and technical assistance on environment and development is¬ 
sues. By merging business and economics expertise, WRI now does work relevant 
to business audiences in environmental accounting, performance measurement, capi¬ 
tal markets, forestry, biodiversity, and climate change. The new merged organiza¬ 
tion will continue programs such as BELL and will launch new educational initia¬ 
tives that will incorporate both environmental leadership, technology and econom¬ 
ics, and science and policy. 7 

Faculty from the science and engineering departments of colleges and universities 
across the country have prepared problem sets and new courses devoted exclusively 
to preventing pollution and have woven prevention concepts into existing courses. 
Engineering faculty teach students how to incorporate pollution prevention in pro¬ 
cess design (Design for Environment), and also how to spot opportunities for waste 
reduction in unit operations. Life cycle analysis is another active area of research in 
which universities are engaged, often as a cooperative research effort with EPA. 

As universities have recognized the need for an interdisciplinary approach to envi¬ 
ronmental studies, they realize that faculty must be prepared to teach these new courses. 
The Tufts Environmental Literacy Institute (TELI) broke new ground in 1990 by of¬ 
fering interdisciplinary professional development on environmental issues for univer¬ 
sity and secondary school faculty. TELI training equips faculty to teach environmen¬ 
tal issues both from an interdisciplinary perspective and with specific reference to 
their own fields. 8 

The Montana State University Extension Service Pollution Prevention Program re¬ 
cently developed a new education guide for Native American colleges. This educa¬ 
tional tool kit for tribal colleges, developed with the guidance of Native American 
educators, includes lesson plans, student guides, instructional materials, and tests and 


6 For more information on the BELL program contact WRI/MEB at 1709 New York Ave., NW, (7th 
Floor) Washington, DC 20006 or call 202-638-6300. 

7 EnviroLink: A Newsletter for Educators in the Field of Business and the Environment (Spring 1996). 

8 Keniry, J. EcoDemia: Campus Environmental Stewardship at the Turn of the 21st Century. National 
Wildlife Federation, Washington, DC (1995). p. 194. 


171 



Chapter 5 - Educational Institutions 


evaluations. It is designed to be used alone as a new course of study or to complement 
an existing natural resources curriculum. 9 

In 1992, the American Institute for Pollution Prevention, together with the American 
Institute of Chemical Engineers and the Center for Waste Reduction and Technolo¬ 
gies, published a compendium of homework and design problems for engineering stu¬ 
dents geared toward pollution prevention issues. 10 

Research and Development 

NPPC has focused its research program solely on life cycle design, life cycle assess¬ 
ment, and industrial ecology. The program’s goal is to guide and enhance environ¬ 
mental decision making through effective metrics, identification and analysis of key 
stakeholder requirements, and selection of resource conservation and pollution pre¬ 
vention strategies. 

The NPPC also has been involved in demonstration projects sponsored by the EPA 
National Risk Management Research Laboratory for the testing and refinement of life 
cycle design techniques. These demonstration projects between the NPPC, EPA, and 
industrial partners have targeted a wide range of products. Automotive products in¬ 
vestigated include oil filters (Allied Signal), air intake manifolds (Ford), fuel tanks 
(GM), automotive film (3M), and instrument panels (Chrysler, Ford, GM, EPA Com¬ 
mon Sense Initiative). Electronic products include business telephones (AT&T), flat 
panel displays (Optical Imaging Systems), and photovoltaics (United Solar Systems). 
Other systems studied range from milk and juice packaging (Dow), to wet technolo¬ 
gies for garment cleaning. 

Carnegie Mellon University developed a university-wide pollution prevention research 
effort, the Green Design Initiative (GDI) (see text box). The GDI consists of interdis¬ 
ciplinary teams whose goal is to prepare new environmental management and pollu¬ 
tion prevention tools for product and process design, policy, and environmental man¬ 
agement. Two main goals are pursued in developing green technologies and policies: 
(1) minimize and effectively manage the use of resources and (2) minimize toxic re¬ 
leases into the environment. 

More than 30 faculty members are involved in GDI research and education. One of 
Carnegie Mellon’s specialties is developing software tools to help engineers design 
environmentally conscious products. The following tools, developed by Carnegie 
Mellon, clarify economic and environmental tradeoffs associated with design choices: 

■ Software to help identify target areas for emission reductions using Superfund 
Amendment and Reauthorization Act (SARA) Title III data. 


9 National Pollution Prevention Center for Higher Education. List-serve Notice dated July, 1996. For 
additional information regarding this educational tool kit, contact Montana State University Extension 
Service at 406-994-3451. 

10 Pollution Prevention: Homework and Design Problems for Engineering Curricula is available 
through the American Institute of Chemical Engineers at 1-800-242-4363. 



Chapter 5 - Educational Institutions 











Green Design Efforts at Carnegie Mellon 

Research activities at CMU involve: 

Green Product Design 

■ The environmental impacts of electric cars 

■ Analysis of battery life cycles 

■ Product design for disassembly and recycling 

■ Component labeling for recycling 

Green Process Design 

■ Systematic synthesis and design methods for cost-effective waste 
minimization 

■ Optimal design and synthesis of power systems 

■ Development of an integrated environmental control model 

■ Modeling chemical emissions from fossil fuel power plants 

Green Chemistry 

■ Environmentally benign and hydrocarbon-soluble oxidants based on 
transition metal chemistry 

Management 

■ Case studies of total quality environmental management implementation 

■ Value chain implications for green products 

■ Economic models of product reuse and remanufacturing 

Green Architecture 

■ The Intelligent Workplace: a working laboratory of environmental 
architecture 

■ Effects of lighting, zoning, and control strategies on energy use 

Sustainable Development 

■ Planning sustainable communities 

■ Economic models of sustainable development 


■ An economic input/output life-cycle analysis tool that links economic input/ 
output tables to environmental data bases to explore the environmental impacts 
of changes in production resulting from fluctuating product demand. 

■ An optimization package designed to find the balance between the amount of 
effort that is put into recycling, reusing, or remanufacturing a component or 
product and the corresponding environmental monetary gains. 


173 





Chapter 5 - Educational Institutions 


■ A design-for-recycling tool that helps assess the difficulty associated with 
product disassembly. 11 

Campus Pollution Prevention Programs 

Campus programs go beyond curricula and research. Campus communities present a 
characteristic set of environmental problems and opportunities for prevention in fa¬ 
cilities management: issues like construction and transportation, power generation, 
heating and cooling, food service and landscaping. On-campus programs offer a su¬ 
perb opportunity for students to get a concrete understanding of the challenges in¬ 
volved in designing and implementing prevention programs. Pollution prevention has 
changed the way in which campus administrators and facility managers think about the 
environmental impacts and economic costs associated with running colleges and uni¬ 
versities. In order to reap the 
benefits of pollution preven¬ 
tion, many administrators re¬ 
alize that they must build 
source reduction and recy¬ 
cling into the fabric of cam¬ 
pus life instead of relying 
solely on student organiza¬ 
tions. Students have pro¬ 
vided abundant enthusiasm, energy, and fresh ideas on how to make pollution preven¬ 
tion work both on campus and in their local communities. For their part, students are 
also looking to campus administrators to carry on the work begun during their years on 
campus. 12 For example, the University of Michigan’s Pollution Prevention Masters 
team completed a campus-wide environmental audit and two subsequent demonstra¬ 
tion projects. 

Begun in the early 1990s, the National Wildlife Federation’s Campus Ecology™ pro¬ 
gram provides tools, guidance, and a support network to help students become in¬ 
volved in environmental issues on campus. 13 Campus Ecology resources include Project 
Resources Packets, workshops, site visits, organizing information, a Campus Envi¬ 
ronmental Yearbook, an environmental job bank, and a newsletter. Campus Ecol¬ 
ogy is accessible and searchable via the Internet (http://www.nwf.org/nwf/cam- 
pus). The program encourages students to coordinate with administrators to de¬ 
velop environmental policies, campus leadership frameworks, and environmental 
centers. 


Campus Ecology™’s Mission 

To establish environmentally sound practices on college campuses by promoting 
leadership and action within the university community. Realizing the impor¬ 
tance of diversity. Campus Ecology strives to include all peoples in working to¬ 
wards environmental solutions, and encourages joint campus and community 
projects. Campus Ecology recognizes the efforts of people who work on outstand¬ 
ing projects by documenting and publishing their accomplishments. 


11 Conway-Schempf, N„ and L. Lave, “Pollution Prevention Through Green Design.” Pollution 
Prevention Review (Winter 1996). pp. 11-20. 

12 Keniry, J. EcoDemia: Campus Environmental Stewardship at the Turn of the 21st Century. National 
Wildlife Federation, Washington, DC (1995). 

13 National Wildlife Federation. Campus Ecology ™: A Campus Outreach Program of the National 
Wildlife Federation (Spring 1996). 


174 



Chapter 5 - Educational Institutions 


Campus Ecology projects include the following: 

I The Environmental Action Committee and the Faculty of Arts and Sciences of 
Harvard University co-sponsored an energy competition among undergraduate 
houses and dorms, saving the school $500,000 in reduced energy use during a 
6-month period. 

■ The Student Government Association (SGA) of Florida Memorial College, a 
private, historically black college in Miami, launched a campus wide recycling 
program, completing the loop by also ensuring that the procurement office 
bought recycled products for the SGA office. The SGA’s efforts won it the 
Leadership for Excellence Award from the City of Miami. 

George Washington University (GWU) in Washington, DC, is one of several universi¬ 
ties that have established a “green” university vision. Unlike most universities, how¬ 
ever, GWU signed a letter of understanding and agreement with EPA to make an envi¬ 
ronmental ethic a part of all activities of the university. The letter of agreement is 
based on the following seven principles: 

1. Ecosystem protection 

2. Environmental justice 

3. Pollution prevention 

4. Strong science and data 

5. Partnerships 

6. Reinventing GWU’s environmental management and operations 

7. Environmental accountability 

GWU has committed to incorporating green concepts into its academic programs, 
research, infrastructure/facilities, environmental health services, international issues, 
and outreach programs. With respect to infrastructure/facilities, for example, the 
university’s mission is to “develop and promote policies, programs, and practices 
that maximize the beneficial effects and minimize the harmful effects of university 
facilities, grounds, infrastructure, and associated operations on the environment.” 
GWU’s Goals and Strategies for Infrastructure/Facilities Management are as follows: 

Long-term Goal: Establish an energy and environmental control function within 

the Facilities Management operating unit of the university. 

Strategies: ■ Create an office of Energy and Environmental Control within 

Facilities Operations, with appropriate personnel assignments. 

■ Develop an energy and environmental management objectives 
program with specific projects identified for implementation. 

Colleges and universities also have taken the lead in developing microscale experi¬ 
ments for students in chemistry laboratories. Dr. Dana Mayo of Bowdoin College and 
Dr. Ron Pike of Merrimack College pioneered the first efforts to design new microscale 
experiments. Working with students and the Ace Glass Company in Vineland, New 
Jersey, the professors manufactured new laboratory equipment that reduces waste. The 


175 




Chapter 5 - Educational Institutions 


Technical 

Assistance Program 
Elements 

Information 

clearinghouse 

■ Research and 
development 

| On-site technical 
assistance 

■ Waste exchange 

■ Waste audits 

| Workshops and 
seminars 

■ Newsletters 

| Awards programs 


results of the microscale revolution at Bowdoin College are impressive. Hazardous 
material use dropped from an average of 300 to 400 milliliters per student to 100 
milliliters per student, and the cost of running the organic labs declined from $8,000 
per lab to less than $ 1,000 per lab due to reduced disposal fees. An unexpected benefit 
was that Bowdoin students’ rate of acceptance to graduate chemistry programs sky¬ 
rocketed because the microscale experiments turned out to be great instructional aids. 

The microscale revolution has since spread throughout the United States and overseas. 
Rice University is phasing in microscale experiments for its 250 undergraduate chem¬ 
istry students. Similarly, the University of Washington has transformed most organic 
experiments to microscale and has begun using products from some experiments as 
reagents for others. Purdue University, with the largest chemistry program in the country, 
started “microscaling” in the 1993-94 academic year, and the University of Michigan, 
which adopted the microscale approach in 1990, recently designed a new building 
around the program. The University of California-Los Angeles, New York Univer¬ 
sity, North Carolina State, the University of North Carolina, Duke University, the Uni¬ 
versity of Wisconsin system, and the Arizona State University system have all begun 
microscale programs within the past 5 years. 14 

Technical Assistance Programs 

The 1994 NPPC directory lists 38 university-based centers for pollution prevention. 
The centers carry out a wide variety of functions including working with industry on 
research and development of pollution prevention technologies, technical assistance 
and outreach to small business, waste reduction audits, data collection, pollution pre¬ 
vention training, and conferences. University-based centers for pollution prevention 
complement similar work being carried out by trade associations and nonprofit organi¬ 
zations such as the Institute of Advanced Manufacturing Sciences and the Pacific North¬ 
west Pollution Prevention Research Center. 


Many pollution prevention centers receive state or federal funding and work with en¬ 
vironmental regulatory agencies to provide technical assistance to local businesses. 
One of the many benefits from these programs is that businesses tend to feel more 
comfortable inviting university students to conduct waste audits than staff from a 
regulatory agency. Many states have both compliance assistance/pollution preven¬ 
tion coordinators in the environmental regulatory agency and a technical assistance 
program in a university. 

The Internet has become a vital mechanism for exchanging information related to 
pollution prevention. As facilities carry out pollution prevention strategies, the need 
to share solutions for specific problems has intensified. In the mid 1990s the Univer¬ 
sity of Wisconsin’s Solid and Hazardous Waste Education Center created a list-serve 
(a specialized/limited access bulletin board or chat room) on the Internet called 
P2TECH. P2TECH serves as an information sharing forum for pollution prevention 


14 Keniry, J. EcoDemia: Campus Environmental Stewardship at the Turn of the 21st Century. National 
Wildlife Federation, Washington, DC (1995). pp. 160-164. 


176 



Chapter 5 - Educational Institutions 


technical assistance provid¬ 
ers. The goal of the Wiscon¬ 
sin program is to foster in¬ 
formation exchange by 
making it easy for pollution 
prevention information to 
be distributed. List-serve 
subscribers post questions 
to the E-mail address: 


List-serves on the Internet 

The University of Wisconsin’s Solid and Hazardous Waste Education Center cre¬ 
ated a list-serve on the Internet called P2TECH, that allows subscribers to ex¬ 
change pollution prevention technical assistance. Subscribers can post questions 
to the e-mail address: p2tech@great-lakes.net and other subscribers can respond 
directly to the question sender. Similar list-serves are available for pollution 
prevention regulations (P2REG), training (P2TRAINER), and pollution preven¬ 
tion for the printing industry (PRINTECH). 


p2tech@great-lakes.net. The 

question is automatically forwarded to other subscribers. If any other subscribers 
know the answer to questions they receive, they can respond directly to the sender or 
can post a response on P2TECH. P2TECH has more than 300 subscribers and the 
number of participants is growing. 


Similar list-serves are available for discussing pollution prevention regulations 
(P2REG), training (P2TRAINER), and pollution prevention for the printing industry 
(PRINTECH). List-serves have proven to be an extremely useful method of sharing 
ideas on vendors, problem-solving approaches, and information sources. The major¬ 
ity of participants are state technical assistance providers but a growing number of 
consultants and federal facility coordinators also have joined. 


The University of Massachusetts-Lowell has developed and maintains the Toxics Use 
Reduction Institute (TURI). TURI is a multidisciplinary research, education, and policy 
center that sponsors and conducts research, coordinates training programs, and pro¬ 
vides technical support to promote education in the use of toxic chemicals. One of 
TURI’s most ambitious projects is P2 GEMS (http://www.uml.edu/turi). P2 GEMS is 
an Internet search tool for facility planners, engineers, and managers who are looking 
for technical and process/materials management information. The site is full text search¬ 
able and includes documents, citations, names of experts, and other resource material 
designed to assist users in pollution prevention efforts. 

In many states, universities are the principal providers of technical assistance to the 
agricultural community. For example, the national Farm* A*Syst program is housed at 
universities. Farm*A*Syst helps farmers and ranchers identify pollution risks from 
nitrates, microorganisms, and toxic chemicals. This program provides both fact sheets 
that describe legal and technical requirements in a format that non-experts can under¬ 
stand and step-by-step worksheets to help landowners apply this knowledge to their 
property. Ultimately, Farm*A*Syst increases use of site-specific management prac¬ 
tices that prevent pollution. The national headquarters of this program is located at the 
University of Wisconsin in Madison. 15 


15 Webpage for Farm*A*Syst. (www.wisc.edu/farmasyst) 


177 








Chapter 5 - Educational Institutions 


What students have 
learned at Dickinson, 
they are giving back to 
their communities. In 
the end, explains 
Professor Michael 
Heiman, "we are 
dedicated to bring 
science to the 
impacted community 
and assisting local 
residents, many of 
whom may not have 
had the chance to go 
to college, to monitor 
the local environment 
by (and for) 
themselves." 


Partnerships in Pollution Prevention 

The growth of pollution prevention research at universities and colleges has been helped 
by partnerships between business/industry and educational institutions. In many in¬ 
stances, the business community has been a significant funding source for university 
research efforts. For example, the University of Illinois Center for Waste Manage¬ 
ment and Research, the University of New Orleans (Urban Waste Management Cen¬ 
ter), Michigan Technological University, Eastern Michigan University, New Mexico 
State University, Clarkson University, and the University of North Dakota have all 
received funding for their pollution prevention programs from industry. 

Businesses and universities are also working jointly on pollution prevention projects. 
One partnership combines the resources of the University of Tennessee, EPA, and 
Saturn Corporation to develop a “green” automobile through a cradle-to-grave study 
of automobile manufacturing. The goal of the partnership is to incorporate environ¬ 
mental concepts in design criteria and eliminate pollution from the manufacturing 
process. 16 University of Tennessee experts will help Saturn develop computer pro¬ 
grams to assess the environmental impact, performance, and economic feasibility of 
different designs and manufacturing materials. 

The Department of Energy also has reached out to the university community to help 
achieve pollution prevention. DOE has established Energy Analysis and Diagnostic 
Centers at universities like Oklahoma State University, where students and engineer¬ 
ing faculty conduct no-charge energy analyses for private companies. By the close of 
1994, more than 5,000 assessments had been conducted and manufacturers had saved 
over $500 million and 94 trillion British Thermal Units of energy. The result was a 
decrease in the emission of harmful greenhouse gases by 200,000 metric tons. 17 

In addition to weaving pollution prevention into the fabric of the campus environ¬ 
ment and curricula, universities are bringing pollution prevention into their sur¬ 
rounding communities. Pollution prevention is a way of bridging the gap between 
academia and town residents as both sides work to protect the local environment. 
Students and faculty have undertaken many different types of outreach projects rang¬ 
ing from courses incorporating Community Right-to-Know data at Dickinson College 
to fireside chats about “living lightly” at Northwestern University. 

Professor Michael Heiman at Dickinson College in Carlisle, Pennsylvania teaches stu¬ 
dents how to use information in EPA’s Toxics Release Inventory (TRI) to identify 
companies’ toxic chemical releases to the environment. 18 Dickinson students tour 
facilities, meet with union officials and community residents, and then prepare envi¬ 
ronmental and epidemiological profiles on the chemicals they track. Students have 


16 Enviro$ense: Pollution Prevention Advisor (First Quarter 1996 ). 

17 U.S. Department of Energy, Office of Industrial Technologies. "DOE’s Industrial Assessment 
Centers, ” (October 1995). 

18 Keniry, J. EcoDemia: Campus Environmental Stewardship at the Turn of the 21st Century. 
National Wildlife Federation. Washington, DC (1995). 


178 



Chapter 5 - Educational Institutions 


audited pulp and paper mills, lead battery recyclers, a soup company, marine boat 
manufacturers, oil refineries, petrochemical companies, and many others. They also 
have used the TRI data base to help affected communities identify toxic waste by 
plant, chemical, and amount shipped offsite to specific waste disposal facilities, as 
well as to track toxic emissions into specific bodies of water and sewage treatment 
plants. 

» 

Recognizing the community empowerment aspects of Dr. Heiman’s project, EPA Re¬ 
gion III awarded Dr. Heiman and his students a grant in 1994-1995 to conduct 18 TRI 
data access workshops for local grassroots environmental groups from low-income 
neighborhoods and communities of color. 

Students at Northwestern University in Evanston, Illinois, have involved both the campus 
community and residents of the city surrounding the campus in environmental protec¬ 
tion through pollution prevention. Students for Environmental and Ecological Devel¬ 
opment (SEED) promotes concern for the planet in community decisions and in daily 
life both through education and action. Two of SEED’S most recent projects are 
Garbology 101 and Living Lightly. 19 

■ Garbology 101 is a demonstration and experiment, which SEED conducts 
annually. Students are given two clear plastic bags to collect their trash and 
recycling for a week in order to get an accurate account of how much waste 
they produce. At the end of the week, participants weigh their garbage. After 
participating in this activity, students are often more motivated to reduce their 
waste generation. 

■ Living Lightly is a project to show people in the Northwestern surroundings 
how they can place fewer demands on habitats and resources. The main 
activity is a series of “firesides,” which are held in dorms on campus. SEED’S 
home page on the Internet lists several references that discuss pollution 
prevention tips. 


NWF’s 12 Benchmarks for Success 

1. Identify and establish executive support. 

2. Develop a written policy. 

3. Identify and maintain resources and incentives. 

4. Create a structure (committee/taskforce). 

5. Integrate programs into the curriculum. 

6. Conduct pollution prevention research. 

7. Incorporate pollution prevention into planning 
and design. 


8. Establish a sense of community. 

9. Measure reductions and demonstrate successes 
in waste reduction and cost savings. 

10. Publicize the program. 

11. Extend environmental ethic to all business 
activities. 

12. Promote leadership development and training. 

Ecodemia — The National Wildlife Federation. 


19 SEED’S home page can be accessed through EPA’s Enviro$ense site (http://es.inel.gov). 


179 








Chapter 5 - Educational Institutions 


As university programs continue to grow in both size and scope, it is important to 
develop a plan that ensures success. The National Wildlife Federation has developed 
a set of 12 benchmarks for the successful development and implementation of envi¬ 
ronmental programs, which can be used in pollution prevention programs. 

Reaching Out to Community and Technical Colleges 

EPA’s Office of Pollution Prevention and Toxics (OPPT), through its Design for 
the Environment (DfE) Program, and the Partnership for Environmental Technol¬ 
ogy (PETE) have combined efforts to create the OPPT-DfE-PETE Environmental 
Education and Training Alliance. PETE helps community and technical colleges 
in developing and delivering quality education and training programs that address 
the nation’s environmental workforce training needs, particularly at the technician 
level. Begun in 1990, the PETE network currently consists of six regional part¬ 
nerships serving all 50 states through approximately 400 participating colleges. 
DfE and PETE are coordinating several activities including developing DfE-P2 
training courses to complement existing industry training programs in fabricare, 
printing, and metal finishing. 20 

Conclusion 

Pollution prevention activities have only recently arrived at educational institutions, 
and it is only in the last couple of years that preventive concepts such as source 
reduction and waste reduction have really taken hold, claiming an equal place with 
conservation, recycling, and environmental studies. Considering how recent they 
are, much has been accomplished, particularly in university R&D and in campus 
programs to reduce waste generation, only a few of which could be highlighted in 
this chapter. Pollution prevention curriculum development has been proceeding 
quickly in the last few years, but is nowhere near standard fare at most universities. 
Networking and exchange of curricula among university faculty is also still at an 
early stage. 

Several lessons learned from the last few years are worth repeating. First, pollution 
prevention’s arrival on campus injects a “real-world” component into university 
courses — from business school to engineering — that benefits students, faculty, and 
partnering organizations. Second, as noted earlier and as Jonathan Bulkley underscores 
in one of the Guest Comments that follow, students have played a decisive role in 
awakening universities to the “green” revolution. That in itself is cause for celebra¬ 
tion, but it also means, as David Allen notes, that the gains achieved on a few cam¬ 
puses must be institutionalized and broadened if they are to take hold and flourish. 


20 For more information on the PETE-DfE alliance contact: David Y. Boon, PETE-DfE Manager, Front 
Range Community College, Westminster, Colorado. 


180 



Chapter 5 - Guest Commentary 


Pollution Prevention and Educational 
Institutions: Next Steps and Long-term Needs 

by 

David Allen 

Beckman Professor of Chemical Engineering 
Center for Energy Studies 
The University of Texas at Austin 

Exciting activities are underway in curriculum development, technical assistance, and campus ecology. While I 
am very enthusiastic about these activities, I do have concerns about their long-term viability. 

Most pollution prevention efforts at universities and other educational institutions have been the result of grassroots 
efforts. Dedicated individuals or small groups, working in isolation, have generally been responsible for the 
activities that are cited in the report. There are, of course, exceptions. The program at Tufts University, which has 
had support from the highest levels of the University Administration, and which has permeated the entire campus, 
is a dramatic counter example. Still, most of the efforts are the result of individuals, and they can disappear as 
quickly as they appeared. Therefore, the next step in promoting pollution prevention at educational institutions 
should be to encourage long-term commitments to pollution prevention. These commitments could be encour¬ 
aged in many ways. Let me suggest some ways to encourage engineering programs to make such long-term 
commitments: 

(1) Have employers demand that the students they hire understand pollution prevention principles. 

(2) Have accrediting boards look for pollution prevention and design for the environment activities in degree 
programs. 

(3) Have new editions of leading textbooks for each discipline incorporate pollution prevention. 

There are just a few simple, self-evident suggestions. My main point is that pollution prevention at educational 
institutions needs to enter a new phase in its development. The past decade has shown us that successful 
programs in curriculum development, technical assistance, and campus ecology can be developed. The goal for 
the next decade should be the make these activities the rule, not the exception. Accomplishing that goal will 
require new approaches. 





181 







Chapter 5 - Guest Commentary 



Student Efforts and Grassroots Initiatives 

by 

Michael Heiman 

Chair Environmental Studies 
Dickinson College 
Carlisle, Pennsylvania 


Despite growing recognition of the need for routine environmental monitoring and enforcement, we live in an 
era of limited state and federal resources. Fortunately, community residents can be trained to directly access the 
regulatory and reporting data required from hazardous chemical generators, handlers, and emitters. Through 
further assistance and access to laboratory facilities of the type common on many college and university campuses, 
local volunteers can also assist in the detection and monitoring of contaminants in their communities. With pollu¬ 
tion prevention beginning at the neighborhood level, in our homes through consumption choices, and at work 
through production decisions, public access to emission data and lay participation with routine background envi¬ 
ronmental monitoring are essential prerequisites if we as a society are to move toward a more sustainable relation¬ 
ship with the environment. 

Congress specifically intended the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA) 
to enable citizens to learn more about the hazardous chemicals stored, used, and released in their communities. 
The EPCRA Toxic Release Inventory (TRI) database provides the major vehicle whereby thousands of environ¬ 
mental activists and toxic victims are finally gaining a handle on the chemical risks to which they are exposed. 
The result has been a flurry of grassroots activities leading to widespread popular support for toxic use reduction 
and more democratic participation in local planning and zoning decisions affecting facility location and expan¬ 
sion. At the national level, access to the TRI data base builds political pressure necessary to strengthen federal 
environmental acts promoting pollution prevention and toxic use reduction, and expanding the list of regulated 
chemicals under the Clean Air and Clean Water Acts. 

The Environmental Studies Program at Dickinson College in Carlisle, Pennsylvania, is committed to this goal of 
grassroots empowerment through faculty and student outreach to affected communities. This is demonstrated 
through our Community Toxic Waste Audit Program and the Alliance for Aquatic Resources Monitoring (ALLARM). 
Both employ Dickinson students working with community volunteers to address requirements for hands-on train¬ 
ing in TRI data acquisition and with routine environmental monitoring. 

The toxic waste audit process is initiated each spring as 75 students in our introductory environmental science 
course prepare audits on communities or facilities of their choosing. The emphasis here is on data acquisition 
and, through plant tours and interviews with production managers, on information concerning progress toward 
pollution prevention, in-plant recycling, and toxic use reduction. The result is that we now run one of the largest 
campus-based toxic waste audit programs in the nation drawn from the TRI data base, and our activities have 
attracted regional and even national attention. 

Supported in 1994-95 by an Environmental Justice Grant administered by EPA Region III, my students and I 
conducted a series of TRI-access workshops in communities of color and low-income neighborhoods heavily 
impacted by toxic emissions. The response was overwhelming. Growing demand for the workshops led us to 


182 






Chapter 5 - Guest Commentary 


prepare a training video geared to accessing the CD-ROM format of the data base, a format that lower-income 
residents are more likely to access atdocal libraries that often lack on-line resources. The data accessed are being 
put to good use in communities such as South West Philadelphia, where a dialogue was initiated with the major oil 
refinery in the region. Most manufacturing concerns prefer to converse with a knowledgeable and informed 
public. Thus negotiations on pollution prevention, source reduction, and a “good neighbor agreement” leading to 
community monitoring of production emissions, are greatly enhanced when each side is apprised of the level of 
information available to the other. We are convinced that the TRI data base remains the single most powerful, yet 
accessible, source of information in the quest for environmental justice, toxic use reduction, and community 
environmental empowerment. 

It is one thing to access industry’s self-reporting via the TRI data base, and quite another to actually monitor the 
environmental quality around a major point of discharge. Community environmental monitoring has grown to 
encompass many thousands of volunteers across the nation. Today there are over 500 groups listed in the EPA’s 
National Directory of Volunteer Environmental Monitoring Programs (4th edition, 1994, Office of Water), the 
majority in existence only since 1990. Often with state and federal financial support, volunteers are trained by 
non-profit service programs such as the Save our Streams Program of the Izzak Walton League. Colleges and 
universities also play a central role, both with training for routine monitoring of pollutants, and with the iden¬ 
tification of environmental quality indicator species such as macroinvertebrates. Institutions of higher educa¬ 
tion can also assist with community access to more advanced analytical equipment for detection of pollutants 
collected by trained local volunteers. 

At Dickinson College, ALLARM, founded by Professor Candie Wilderman, runs one of the largest volunteer 
monitoring programs in the nation. Staffed by students, ALL ARM involves over 500 local participants across 
Pennsylvania who test weekly for acidity and buffering capacity in their local streams. ALL ARM staff can supply 
a “toxic fingerprint” for heavy metals and hydrocarbons based on water samples collected by local volunteers, 
with the results helping to identify water discharges that may not appear on the TRI reports. With appropriate 
quality control assurance, and providing a much denser spatial and temporal matrix of sampling sites than possible 
with over-taxed public agencies, many states have come to rely upon volunteer monitoring to meet the biennial 
water quality reporting requirements of section 305(b) of the Clean Water Act. 

Encouraging our students to work as multidisciplinary research teams in a real-world setting; helping them 
acquire both technical skills and social self-confidence as they network with industry, residents, labor, and 
regulatory personnel; and building bridges between the campus and the wider community, are critical goals for 
our program. We are convinced that colleges and universities have a vital role to play as they assist local 
communities and organizations download existing information and monitor the background conditions neces¬ 
sary to measure progress toward pollution prevention and toxic use reduction. 


183 



Chapter 5 - Guest Commentary 


Pollution Prevention and tlie Challenge for 
Higher Education 

by 

Jonathan W. Bulkley 

Director 

National Pollution Prevention Center 
University of Michigan 
Ann Arbor, Michigan 

Environmental protection efforts on campuses have been developed in many different ways over the past 
five years. My direct experience has been conditioned by what I have observed as a faculty member at the 
University of Michigan. At the same time, as Director of the National Pollution Prevention Center for 
Higher Education, there have been opportunities to gain appreciation of what is taking place on other cam¬ 
puses around the country. One common thread, which it is important to highlight is the increased awareness 
of and commitment to pollution prevention by the students in a wide range of disciplines. This awareness of 
and commitment by students manifests itself in a variety of ways. For example, student project teams have 
examined pollution prevention and waste reduction opportunities at different locations both on-campus and 
off-campus ranging from implementation of chemical tracking systems at universities, pollution prevention 
and waste reduction initiatives for an entire school within a major university, to pollution prevention and 
waste reduction opportunities for major collegiate sporting events, and less polluting alternatives for dry- 
cleaning. The students and faculty who undertake these and many similar types of projects demonstrate the 
vitality of promise of pollution prevention activities at colleges and universities across the country. 

In my view, certain pollution prevention and sustainable development activities in industrial settings have 
moved ahead of the present curriculum in many colleges and universities. In part, this is the result of the 
economics associated with waste clean-up and other associated liabilities. Accordingly, it is desirable for 
colleges and universities to establish enhanced linkages with pace-setting industrial locations where very 
innovative and creative pollution prevention activities are underway. The linkages can take a variety of 
forms including joint faculty-industry research efforts, student pollution prevention internships with indus¬ 
try, faculty joining industry for special projects/tasks, and industry leaders teaching innovative courses at 
colleges and universities. 

One specific example of this type of industrial leadership is in the development of the concept of Industrial 
Ecology. While the origins of Industrial Ecology may be traced to the systems approach to problem formu¬ 
lation and problem analysis, the specific concept is attributed to Robert Frosch and Nicholas Gallopoulos 
from the General Motors Corporation, in their article, Strategies for Manufacturing, (Scientific America 
261: September 1989, 144-152). At the time, Robert Frosch was a Vice-President of General Motors; now, 
he is a faculty member at the Kennedy School of Government, Harvard University. A team led by Dr. 
Thomas E. Graedel at Lucent Technologies (Bell Laboratories) has been very instrumental in the substan¬ 
tive development of the concept of Industrial Ecology and its application in real world settings. In addition, 
Dr. Graedel and Dr. Allenby, also of Lucent Technologies, have published the first textbook on Industrial 
Ecology and it is being used at several universities (Graedel, T.E. and Allenby, B.R., Industrial Ecology. 
Prentice-Hall, New York, 1995). Through the innovative support program of the AT&T Education Founda¬ 
tion, a number of key Industrial Ecology initiatives at colleges and universities in this country and overseas 



184 










Chapter 5 - Guest Commentary 


have been implemented. This type of creative and constructive activity between colleges/universities and 
industry need to be emulated and expanded. 

In undertaking the implementation of pollution prevention programs, colleges and universities have both 
unique opportunities and unique challenges. On the one hand, there is an able and active student body whose 
interests and energy is ready to help advance such programs. As with any institution, there are other real 
forces which act to inhibit change and the implementation of new ideas and concepts. Faculty members may 
want to alter their courses to include new concepts on pollution prevention and sustainable development. 
However, these new materials need to be provided to the faculty in ways which facilitate the utilization of 
these new materials by the faculty member. Constraints associated with meeting accreditation requirements 
may limit the rate of change of introduction of pollution prevention/sustainable development curricular ma¬ 
terials into such accredited programs. Faculty research opportunities in pollution prevention/sustainable 
development from funding sources such as the National Science Foundation (NSF) and other key institutions 
funding research need to be established and extended. In the long term, the compiling of research activities 
and curricular development results in the enhanced education of students in the area of pollution prevention/ 
sustainable development. These students will then bring these ideas/concepts to their workplace and the 
likelihood of significant progress being made will be greatly enhanced. 

From a personal view, on this campus there are two pollution prevention activities which I have observed that 
are both exciting and productive. First, in a number of sponsored research pollution prevention projects, a 
diverse group of students have come together to work in a very productive and useful way. The key to this 
success is the leadership offered by the director of the research effort. Through leadership and excellent 
insights, the research team leader sets the example that draws the very best efforts from all who work on the 
research projects. These research efforts stand as excellent examples of the creative and constructive results 
that can be achieved in this field. 

A second example again relates to students. In this case, the NPPC has experience with the placement of 
pollution prevention interns in industry, not-for-profit organizations, and government. The quality of effort 
by these young people from a variety of backgrounds, disciplines, and universities has clearly demonstrated 
that a group of exceptionally talented and capable young people are coming forward to work and help solve 
these problems that need pollution prevention and sustainable development concepts and approaches. I am 
very optimistic that the students of today who will be the leaders in the twenty-first century will rise to the 
challenges and provide pathways to achieve pollution prevention and sustainable development. 


185 




Chapter 5 - Educational Institutions 


186 



Chapter Six 

Tlie Contributions of 
Community and Non-Profit 
Organizations 


■ Two Tools for Communities 

■ Community Issues and Initiatives 

■ National Non-Profit Organizations 

■ Guest Comments: 

Paul Orum, Working Group on Community 
Right-to-Know 

Mary Rosso, Maryland Waste Coalition 

Naomi Friedman, National Association of 
Counties, and 

Karen Troccoli, National Association of 
County and City Health Officials 





Chapter 6 - Community and Non-Profit Organizations 


188 




Chapter 6 - Community and Non-Profit Organizations 




Introduction 

In the past, the phrase “pollution prevention” has been most closely associated with 
industrial processes, so much so that many have been led to believe that pollution 
prevention is exclusively an industrial matter. Indeed, community involvement in 
pollution prevention has primarily been in an industrial context. For example, com¬ 
munities have worked with facilities to get them to lower their emissions of toxic 
substances and prevent risk. 

But just as pollution is not solely the fault of industry, preventing pollution is not 
solely the responsibility of industry. In 1990, EPA’s Science Advisory Board (SAB) 
published “Reducing Risk,” a report which advised the Agency on how to prioritize 
efforts to address the most serious risks to human health and the environment. One 
of the challenges the SAB acknowledged is the diverse sources of pollution: 

“Action by individuals regarding where to live and work, what prod¬ 
ucts to buy, and what activities to pursue have collective impacts on 
local, regional and global environmental systems. Most large point 
sources of pollution have now been addressed. The remaining sources 
of pollution resulting from general economic activity and lifestyle de¬ 
cisions are numerous and now are major contributors to many environ¬ 
mental problems. In total, they are causing unprecedented changes to 
the biosphere.” 1 [emphasis added] 

Problems resulting from dispersed sources of pollution (for example, automobile 
emissions or run-off from cities, suburbs and agricultural lands) are more difficult to 
control with traditional “end of pipe” measures than are large, industrial sources of 
pollution. Moreover, the resources of a given place — air, water, land, and living 
organisms (plants and animals) — need to be treated as inter-connected parts of a 
system. And finally, not all parts of the country have the same problems or need the 
same kind of solutions. EPA’s approach to the challenges facing communities — 
called Community-Based Environmental Protection (CBEP) 2 — is to assess and man¬ 
age the quality of air, water, land, and living resources in a place as a whole, to reflect 
regional and local conditions, and to work with public and private partners in environ¬ 
mental protection. In addition, innovative approaches in applying pollution preven¬ 
tion solutions to the problems faced by minority and low income communities have 
been supported by EPA’s Environmental Justice through Pollution Prevention (EJP2) 
grants program, an initiative of Administrator Carol Browner. Since 1995, EPA has 
awarded nearly 100 EJP2 grants, primarily to non-profit organizations and tribes. 

Pollution prevention can be most meaningful to communities when it is viewed as a 
strategy for pursuing sustainable development. In order to achieve sustainability, pro¬ 
ductivity, jobs, profits, information, and education must grow, while pollution, 


"It is within 
communities that 
people can most easily 
bring diverse interests 
together, identify and 
agree on goals for 
positive change and 
organize for 
responsive action... 
Local communities 
offer people the 
greatest opportunity 
to meet face to face to 
fashion a shared 
commitment to a 
sustainable future." 

— The President’s Council 
on Sustainable 
Development 


i 1 EPA. Reducing Risk: Setting Priorities and Strategies for Environmental Protection. (SAB-EC-90- 
021, September 1990). 

2 EPA’s homepage, “www.epa.gov” 

189 





Chapter 6 - Community and Non-Profit Organizations 


waste, poverty, and energy use and natural resource consumption must decrease. Pol¬ 
lution prevention strategies at the community level can be enhanced by integration 
with environmental planning and management approaches that emphasize integration 
of social, economic, and environmental factors. 

This chapter examines two influential forces in the progress of prevention in the 
United States — activities of communities and non-profit organizations. The first 
part of this chapter examines a number of issues facing communities for which pol¬ 
lution prevention provides a constructive and promising set of solutions. They in¬ 
clude issues of transportation and land use, local economic self-sufficiency, and build¬ 
ing design/indoor air quality. A concluding section of this chapter reviews the im¬ 
portant role played by national non-profit organizations in advancing the cause of 
pollution prevention. 

Two Tools for Communities 

“Think Globally, Act Locally,” a popular bumper sticker reads. How should we “act 
locally?” How do communities with diverse environmental problems know where to 
start? 

Community Partnerships for Environmental Action 

In conjunction with EPA, the Maryland Department of the Environment, Baltimore 
and Anne Arundel County are now participating in a new initiative to develop a 
partnership with local neighborhoods and businesses to pilot a community-based 
approach to environmental protection. The project is designed to achieve the 
following: 

■ Address environmental issues from the perspective of the neighborhood. 

■ Develop a detailed environmental/risk profile using information from all 
partners. This approach allows for the consideration of information often 
missed when policy is made at the national or state level. 

■ Empower the community to take the lead in the decisions affecting their 
environment. 

■ Allow communities to develop pollution prevention approaches that go 
beyond current statutory requirements. 

■ Set an environmental action agenda based upon the needs and wants of the 

community. The Rockefeller University recently published a case study on how a 
CRP might be conducted for the Silicon Valley area of California, rejecting the idea 
that environmental health risks can actually be numerically ranked. The proposed 
goal of the CRP for Silicon Valley, which would be developed by a community task 


Community-based initiatives 
have a variety of tools with 
which to identify environ¬ 
mental problems and poten¬ 
tial solutions. Two of these, 
community risk profiles 
(CRPs) and visioning, are 
described here. 

The Rockefeller University 
recently proposed that com¬ 
munities use CRP as a tool 
to improve environment and 
community health. 3 Unlike 
a comparative risk assess¬ 
ment, a CRP does not rank 
risks but rather provides a 
method to determine how 
best to serve the needs of a 


190 


1 The Rockefeller University. Community Risk Profiles: A Tool to Improve Environment and 
Community Health , prepared for the Robert Wood Johnson Foundation (April 1995). 



Chapter 6 - Community and Non-Profit Organizations 


force representing an ethnically and socially diverse cross section of community lead¬ 
ers, is not to determine which risks are the most important, but to provide a tool to 
make it easier for decision-makers to consider specific courses of action. Decision¬ 
makers will have other non-environmental factors to consider when deciding how to 
address these environmental issues, including the values of the community, economic 
forecasts, and social and economic priorities of the community. 

The Silicon Valley task force might list environmental hazards it is concerned about — 
agricultural chemicals, automotive air pollution, and fireplace smoke might be three 
such hazards. The task force would then evaluate these hazards based on criteria such 
as how toxic the pollutant is to specific exposed populations, what type of health risks 
are involved, what type of ecological risks are involved, what kind of economic im¬ 
pacts possible resolutions to the environmental problem would entail, and general quality 
of life issues. CRPs provide a transparent, systematic method for evaluating the envi¬ 
ronmental concerns of a community so that whatever program the community devel¬ 
ops has a solid base of support. 

Another way to build a strong foundation for a community project is to use a “vision¬ 
ing” process. This process is a public participation strategy that allows an entire 
community to develop a shared “vision” for their community’s future. The process is 
characterized by a high level of community participation, within a series of open, 
inclusive public meetings. Through this collaborative process, the community agrees 
to mutual values and goals. These goals then become the guiding force for changes 
in the environment, transportation, economic development, education, recreation, etc. 
The visioning process is a tool to help further community sustainability, yielding an 
improvement in the community’s overall quality of life. The consensus-building ap¬ 
proach of a visioning process often ensures smoother implementation and more effec¬ 
tive long-term results. 

Chattanooga, Tennessee employed this visioning process very successfully. Using this 
process, Chattanooga went from being named the “worst polluted city in America” in 
which cars often needed to use headlights during daylight hours in order to see through 
the heavily-polluted air, to a clean, healthy area which proudly markets itself as an 
“environmental city” because of its attention to quality of life issues like increased 
parkland and a revitalization of the historic downtown area. 4 

In addition to CRPs and visioning, communities can make use of a broad range of 
ecosystem tools (e.g., ecological risk methodology, ecological assessments, GIS mod¬ 
eling programs, etc.) social tools (e.g., community profiling methods), and economic 
tools (e.g., “build out” scenarios, ecosystem benefit identification methods, etc). 
Many specific tools can be found at one of EPA's web sites (http://www.epa.gov/ 
ecocommunity/). 


Another way to 
build a strong 
foundation for a 
community 
project is to use a 
"visioning" process. 


4 The President’s Council on Sustainable Development. Sustainable America: A New Consensus for 
Prosperity, Opportunity, and a Healthy Environment. (February 1996.) 


191 








Chapter 6 - Community and Non-Profit Organizations 


Community Issues and Initiatives 

Prevention in the Transportation Sector 

Cars are by far the most popular way of getting from one place to another in the United 
States. As of 1993, there were an estimated 196.8 million cars in the country -- ap¬ 
proximately one for every eligible driver in the country. 5 This proliferation of car 
ownership has brought tremendous freedom of movement, as well as tremendous pol¬ 
lution. Since passage of the Clean Air Act in 1970, federal emission control policies 
have become progressively more stringent. These efforts have greatly reduced typical 
vehicle emissions; however, in those same years, the number of miles driven has more 
than doubled. The increase in travel has offset much of the emission control progress. 

The effects of cars on the environment extends beyond air pollution to larger issues of 
land use, urban sprawl, and the degradation of watersheds and remaining underdevel¬ 
oped areas, as well as hazardous waste management issues related to the disposal of 
used motor oil, antifreeze, and batteries. One EPA report noted: 

“Emissions from an individual car are generally low, relative to the 
smokestack image many people associate with air pollution. But 
in numerous cities across the country, the personal automobile is 
the single biggest polluter, as emissions from millions of vehicles 
on the road add up. Driving a private car is probably a typical 
citizen’s most polluting daily activity.” 6 

Transportation problems are complex, involving federal and state policies and funding 
mechanisms, environmental quality and safety, economic issues relating to congestion 
and mobility, and local land use and development concerns. 

Below are some interesting, diverse examples of how local governments and/or com¬ 
munity organizations have found preventive solutions to transportation and land use 
issues. These examples also illustrate the variety of local organizations that are 
involved in the transportation planning process (e.g., cities, school boards, non-profit 
organizations, etc.). 

■ The Tri-State Transportation Campaign is a non-profit corporation that 
strives to reform transportation systems and policies in the 32-county New 
York/New Jersey/Connecticut region. The Campaign engages the region’s 
transportation agencies in policy level dialogue and works to influence planning 
in project areas critical to the region’s transportation future. The Campaign’s 
1996 project agenda focuses on five issues: pedestrian advocacy, sound land 
redevelopment strategies, alternative fuel bus fleets, mass transit defense, and 
highway expansion alternatives. 7 


5 National Safety Council (Department of Transportation) statistic (number of registered vehicles in 

1993) . 

'’EPA, Office of Mobile Sources. Automobile Emissions: An Oven’iew (EPA 400-F-92-007, August 

1994) . 


192 




Chapter 6 - Community and Non-Profit Organizations 


I After two years of research and development, the Southeast Community 
Development Corporation, a unique alliance of eight southeast Los Ange¬ 
les County cities, will soon launch the Smart Shuttle. SCDC aims to 
enhance commercial and manufacturing districts, increase employment and 
training opportunities, and regional economic growth. The Smart Shuttle is 
the first Los Angeles alternative fuel advanced communication technology 
shuttle founded by a community-based organization. The idea is to develop a 
mode of public transportation that will get commuters out of their cars, while 
providing easy connections with the Metro rail systems. The shuttle’s ad¬ 
vanced communication programming capability will allow it to selectively 
route itself to provide efficient, prompt, and flexible service. By avoiding 
heavily congested highways and reducing the amount of cars on the highways, 
the Smart Shuttle will help Southern Californians reduce air pollutant emissions. 

I The goal of the Land Use, Transportation, Air Quality Connection Pro- 

I gram, which was initiated by 1000 Friends of Oregon (a non-profit public 
service organization), was to develop viable alternatives to a proposed 
highway bypass in Portland, Oregon. By 1995, LUTRAQ succeeded in 
convincing the Oregon Department of Transportation (ODOT) to scrap plans 
for the bypass and replace it with a plan which consisted of light rail transit, 

I high-frequency bus service and walking/biking facilities. ODOT concluded 
the LUTRAQ plan had the least negative environmental and social impacts of 
all the proposed alternatives, and incorporated it into the region’s 50-year land 
use and transportation plan. 8 

I EPA’s Transportation Partners Program promotes and supports voluntary 
local programs (like those mentioned above) that reduce greenhouse gas 
emissions from the transportation sector by improving transportation 
choices and efficiency. 9 The program concentrates on three major areas: 1) 
community design which makes it easier to walk, bike, or take transit; 2) 
market incentives that reduce congestion such as discounted off-peak tools, 
reducing parking subsidies, and encouraging private transit services; and 3) 
technology applications that take advantage of cutting edge technologies such 
as telecommuting and enhanced and flexible transportation services. The first 
annual Transportation Partners’ Way to Go! awards were presented to eight 
organizations in September 1996. 

I Cincinnati, Ohio is committed to “greening” its own road maintenance 
program. The Department of Public Works/Highway Maintenance Division 
and Parking Facilities Division converted to lead-free, waterborne paint for 


Tri-State Transportation Campaign Homepage (http://www.tstc.org/tstc/) 

EPA. Way to Go! Awards Summary, p. 6. 

'EPA. Smart Moves for Healthier Communities [brochure], (EPA 230-F-96-003, August 1996). 

193 

i 









Chapter 6 - Community and Non-Profit Organizations 


yellow and white highway as well as parking lot line striping instead of 
leaded, solvent-based paint. The paint conversion is an example of avoiding 
costs associated with media- and chemical-specific regulations. The switch 
from high-VOC solvent-based paints avoids the stricter federal regulations 
anticipated in the near future. Cincinnati is clearly ahead of the game in this 
situation and is already benefiting from cost savings, reduced employee 
exposure, and a cleaner environment. Based on an annual use of 22,000 
gallons of line stripe paint, approximately 33,000 pounds of lead and 36,000 
pounds of VOCs are being eliminated from Cincinnati’s environment each 
year through this conversion. 10 

Integrating Prevention with Land Use, Economic Development, and 
Environmental Justice 

For many communities faced with a dwindling industrial base, disadvantaged com¬ 
munities, abandoned commercial facilities, and a variety of other economic travails, 
pollution prevention offers the possibility of building sustainable and self-sufficient 
economic communities while improving the ways in which land and other natural 
resources are used and developed. 

Eco-Industrial Parks. One emerging concept is the development of eco-industrial 
parks (EIPs), which link a variety of manufacturing and service businesses into an 
“industrial ecosystem.” These parks embody ecological principles to achieve the 

Northampton County, Virginia’s Sustainable Development Action Strategy. 

In response to severe economic conditions, Northampton County designed an aggressive plan of action, the Sus¬ 
tainable Development Action Strategy, to simultaneously invest and protect its natural resources and cultural assets 
to build a strong and lasting economy that will benefit all of its people. The County’s commitment and accomplish¬ 
ments have earned national recognition as a model for the real and lasting development of communities across 
America. The Strategy consists of a coordinated program of specific achievable objectives, each of which is 
simultaneously an economic development action and a resource protection action. The Strategy targets six indus¬ 
try areas with immediate and ongoing potential to provide quality job and business opportunities. Each of these 
industries depends on one or more fundamental vital assets for its initial development and ongoing success, as 
follows: agriculture/productive land; seafood and aquaculture/clean water; heritage tourism/preserved natural and 
cultural resources; arts, crafts, and local products/culturally-diverse and authentic community; research and educa¬ 
tion/intact natural and cultural systems; and new industry/sense of place, quality of life, fresh water. The Northampton 
County Sustainable Development Action Strategy has been characterized by the community as being good for 
business, good for the environment, and good for all of its people. 

most beneficial, least damaging interaction with the environment. By integrating all 
aspects of environmental management into one site, an eco-industrial park offers a 
system where the consumption of energy/materials is optimized, waste generation is 
minimized, and byproducts of one process serve as the raw material for another process. 


10 The City of Cincinnati’s Pollution Prevention Program. (September 30, 1996). 
194 




Chapter 6 - Community and Non-Profit Organizations 


Environmental benefits of EIPs include lower pollution emissions from facilities, 
conservation of natural resources, and fewer threats to public health. EIPs also pro¬ 
vide an opportunity to demonstrate innovative approaches to pollution prevention, 
energy efficiency, resource recovery, product disassembly, and other advanced envi¬ 
ronmental technologies. 

EPA is encouraging local participation in the development of EIPs, since the needs 
and environmental protection issues for each park will be unique. Chattanooga, 
Pittsburgh, and Baltimore are three cities that are working hard to develop successful 
EIPs that are tailored to their local needs. By encouraging community participation 
and involvement in the development and operation of the EIP, companies can build 
public support and demonstrate their commitment to environmental protection. 

The border community of Brownsville, Texas, is working to expand the definition of 
EIP to include the whole community. Brownsville and its sister city of Matamoros 
(Mexico), are negotiating how to plan and execute a EIP that benefits both communi¬ 
ties and properly uses the concept of EIPs to gain full environmental benefits. 

While EIPs are an exciting concept, implementation at the community level is just 
beginning and will take some time to develop. During the interval, however, com¬ 
munities are benefiting greatly from more targeted pollution prevention programs 
aimed at specific problems. 

Brownfields. Land use and economic development come together in the problem of 
“brownfields” — abandoned, idled, or under-used industrial and commercial facilities 
v/here redevelopment or expansion is complicated by real or perceived environmental 
contamination. EPA has launched a Brownfields Initiative to empower states and com¬ 
munities to prevent, assess, clean up, and sustainably reuse brownfields, with the goals 
of a cleaner environment, new jobs and tax base, and preservation of undeveloped, 
forested “greenfields.” 

Environmental Justice. Another area where pollution prevention is being integrated 
into economic development issues is in “environmental justice” communities. EPA’s 
environmental justice program was developed in response to a 1992 study 11 that found 
that people of color and low-income communities experience higher exposure to 
toxic pollutants than the general population. For example, most hazardous waste 
treatment and disposal sites are located in poor and minority neighborhoods. Be¬ 
cause many such communities face disproportionate environmental impacts, local 
pollution prevention programs can help eliminate the need for current and future 
treatment and disposal systems, while in some cases producing jobs and sustainable 
businesses. 


"Communities of 
color and low 
income Americans 
seek not to 
redistribute 
pollution from 
dirtier and 
overexposed areas 
to cleaner and 
underexposed 
areas. They, 
instead, seek to 
prevent pollution 
at the source so 
that all Americans 
can breathe clean 
air, drink clean 
water, and eat 


EPA’s EJP2 grants program supports local environmental, environmental justice, com¬ 
munity grassroots organizations, and tribal governments that promote environmental 
justice using pollution prevention as the preferred approach, as well as national and 






clean food." 

- Representative 
John Conyers 


"This study is described in INFORM’s Toxics Watch 1995. 


195 




Chapter 6 - Community and Non-Profit Organizations 


regional organizations that partner with such groups. Following are some examples 

of projects that have been funded over the last two years: 12 

■ WE ACT/Natural Resources Defense Council received an EJP2 grant of 
$200,000 to assist Northern Manhattan communities that are disproportion¬ 
ately impacted by excess levels of airborne particulate matter and toxins from 
multiple sources. The grant will address air pollution from buses and trucks, air 
pollution and improper waste disposal by dry cleaning operations, the lack of 
accurate commercial and industrial sites information, and keeping brownfields 
clean through pollution prevention. The proposal includes four program 
initiatives: 1) Uptown Diesel Bus Initiative; 2) Dry Cleaning Initiative; 3) 
Commercial and Industrial Sites Audit; and 4) Keeping Brownfields Clean 
Initiative. 

■ Citizens for a Better Environment (CBE) won a $148,987 EJP2 grant. The 
regional non-profit organization plans to use the grant funding to provide much 
needed technical and financial support to local grassroots organizations as they 
work to foster pollution prevention in their communities in Chicago, Milwau¬ 
kee, and Minneapolis. All of the neighborhood CBEs will be focusing on 
communities of color with the majority of their residents living in low-income 
households. Project activities will include: providing technical assistance to at 
least two local organizations in Southeast Chicago to establish good neighbor 
dialogues with polluting businesses; work with four partners to foster model 
pollution prevention efforts among auto repair and metal fabricating businesses 
on Milwaukee’s south side; and work with the Hawthorne community of 
Minneapolis, a low-income neighborhood to engage in permit monitoring of 
neighborhood facilities, and the establishment of Good Neighborhood Dia¬ 
logues between residents and businesses. 

■ In EPA Region I, a coalescing of environmental justice projects is occurring in 
Boston, focused on the increasing hazards posed by small automotive shops 
located in low-income neighborhoods. Health centers in these neighborhoods 
have reported startling incidences of accidental direct and indirect exposure of 
the public to local automotive shop toxins. The Bowdoin Street Health Center 
received $53,450 to add a Certified Industrial Hygienist to the community 
health center’s occupational health clinic. The industrial hygienist will help 
small area automotive repair/bodyshops and dry cleaning businesses comply 
with all regulations and decrease the amount of hazardous and toxic sub¬ 
stances they use. The Department of Health and Hospitals also received 
$53,450 to develop a 15 to 20 minute training film for auto shop owners on 
how to establish and maintain sound environmental pollution prevention 
practices. Viewing of the film will be required as part of the city’s auto shop 


12 EPA. “Pollution Prevention Offers Solutions in Environmental Justice Communities.” Pollution 
Prevention News (April/May 1997). For more information on the EJP2 grants program, contact Chen 
Wen in the EPA Pollution Prevention Division at 202-260-4109. 


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Chapter 6 - Community and Non-Profit Organizations 


permitting process. Other educational and outreach efforts related to automo¬ 
tive shops are being conducted by NEWMOA (the Northeast Waste Manage¬ 
ment Officials Association) and a joint collaboration of Roxbury Community 
College and the Tellus Institute in the Roxbury neighborhood of Boston. 

■ Dry cleaners are another small business concern with heavy minority ownership 
and environmental impacts in low-income neighborhoods. One EPA Region IX 
project focused on Korean-American dry cleaners who make up close to 70 
percent of the industry in the greater Los Angeles area, and roughly 60 percent 
of the industry nationwide. The project brings together the Korean Youth & 
Community Center, UCLA’s Pollution Prevention Education and Research 
Center, and Clean by Nature (Southern California’s first 100 percent wet 
cleaning shop) to develop a wet cleaning outreach and education program. 

■ The EJP2 grant program offers the opportunity for more innovative approaches 
to environmental justice. For example, in EPA Region X, the Tulalip Tribes of 
Washington State received $196,614 to take a closer look at the competing 
demands of economic development and environmental protection, using 
sustainable development and pollution prevention as the focus. One outcome of 
the project will be a model Tribal Environmental Policy Act (TEPA) that tribes 
can use to review proposals for economic development near reservations. 
Another new approach funded through the grant program is a revolving fund 
operated by the National Association of Community Development Loan Funds 
(NACDLF) which represents 46 private, non-profit community development 
financial institutions that provide credit, capital, and technical assistance to 
support the revitalization of low-income rural, urban, and reservation-based 
communities across the United States. The fund will provide seed capital to 
several small community development organizations businesses, as well as 
providing training to its member institutions. 

Adopting Environmental “Best Practices” 

A large number of communities are undertaking pollution prevention activities as 

part of “best practice” environmental measures in areas ranging from water monitor¬ 
ing to leaf burning. Examples include: 

■ Broward County, Florida, Department of Natural Resource Protection, in 
1992, created the first pollution prevention best management practices 
program for marine facilities. Boat repair and maintenance activities have 
the potential for contaminating surface and ground waters with discharges and 
runoff. Technical teams assessed the environmental impacts of the marine 
industry operations and worked closely with industry representatives to 
develop requirements and goals for all marinas. The goal was to encourage 
compliance with the Broward County Environmental Code. Workshops for all 
stakeholders were held and resulted in improved environmental regulation 


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Chapter 6 - Community and Non-Profit Organizations 


compliance, enhanced waste minimization practices and a pollution preven¬ 
tion attitude in the marine industry. 13 

■ Lincoln-Lancaster County, Nebraska, has initiated two pollution 
prevention programs: The Wellhead Protection Project, and the Clean 
Community System. The Wellhead Protection Project is funded through 
grants to identify village well recharge areas and potential sources of 
contamination to prevent future pollution. On-site farm pollution preven¬ 
tion assessments are being conducted in wellhead protection areas. The 
Clean Community System is taking a grassroots approach to educating 
citizens pollution prevention. The goal of the education displays and 
activities conducted at county and state fairs is to help citizens identify and 
prevent nonpoint source pollution. Volunteers are stenciling storm drains 
with “No Dumping” and “Goes to Stream” slogans. 14 

■ The St. Clair County Health Department, Illinois, in collaboration with the 
American Lung Association, Illinois Soil and Water Conservation District, 
Illinois Nurses Association, and area hospitals, is identifying alternatives to 
leaf burning and educating the public about sound leaf management. The 

City of O’Fallon, Illinois is using a vacuum to manage leaves and is demonstrat¬ 
ing the process for other communities on leaf composting. Freeburg, Illinois, is 
using a small machine to mulch leaves as they are collected. The leaves will be 
used by farms. County firemen are assisting in educating students on the 
environmental and health problems associated with leaf burning. 15 

Preventing Pollution in the Indoor Environment 

Most of us spend considerably more time indoors (either in our offices and in our 
homes) than we do outside; some studies have indicated that the average person 
spends as much as 90 percent of the day indoors. Because we spend so much time 
indoors, indoor air concentrations, even if uniformly lower than outdoor levels, make 
up a significant amount of our exposure every day. In fact, complaints about inad¬ 
equate indoor air quality are escalating. 

Indoor air pollution is especially important to those who work in professions that 
expose workers to chemicals such as formaldehyde, perchloroethylene, and solvents 
that can cause serious health concerns. The 1990 SAB report identified indoor air 
pollution as one of four environmental issues that represented major types of human 
exposure known to be associated with significant impacts on human health. 


13 Preventing Pollution in Our Cities and Counties: A Compendium of Case Studies. A joint 
publication of the National Association of County and City Health Officials, the National Association 
of Counties, the National Pollution Prevention Roundtable, the Municipal Waste Management 
Association, and the United States Conference of Mayors (Fall 1995). 

14 Ibid. 


198 


15 Ibid. 





Chapter 6 - Community and Non-Profit Organizations 


Indoor pollution from such sources as tobacco smoke, radon, and asbestos, and expo¬ 
sure to toxic agents in consumer products (e.g. solvents, pesticides, formaldehyde) 
can cause cancer and a range of non-cancer health effects. Table 6-1 summarizes the 
major indoor pollutants, their sources, and their possible health effects. 

At the federal level, the EPA’s Office of Radiation and Indoor Air is responsible for 
developing policy and programs dedicated to reducing the risks associated with these 
pollutants. In addition, the Occupational Safety and Health Administration (OSHA) 
sets standards for occupational exposure to many of these pollutants. Beyond EPA 
and OSHA, each state has a department of natural resources, environment, or health 
which deals with indoor air pollution. In addition, some counties have their own 
pollution agencies focusing on this issue. In some cases, local communities start a 
program with the technical assistance and funds from the federal government and move 
on to develop their very successful programs. For example: 

■ The Austin, Texas, Green Builder Program’s roots were in Austin’s Energy 
Star Program, which developed out of EPA’s own Energy Star Program. 

The Green Builder Program rates homes on their environmental soundness. For 
example, a highly rated home might include filtration systems that reduce 
particulates by 40-80 percent and better. In addition, houses would include a 
higher grade of plywood which reduces formaldehyde emissions. The rating 
system raises awareness of and promotes green building practices. Austin has 
devoted considerable resources to making this program a success, renting 
billboards to advertise the program and teaming up with Habitat for Humanity 
(the nation’s fourth largest builder) to further raise the profile of the program. 

■ Recently, the San Francisco Water Pollution Prevention Program became 
involved in preventing indoor pollution and published a prevention guide 
for businesses, “Managing a Less Toxic Building: Pollution Prevention Tips 
For Commercial Office Buildings. The guide includes advice on chemical 
storage, water and energy conservation, and painting. While the focus of the 
guide is to prevent pollution in the public water system, many of the measures 
will decrease indoor pollution as well. For example, using latex paints when¬ 
ever possible will reduce the need for paint thinners (latex paints do not 
require thinners or solvents for cleanup) and thus will help reduce organic 
gases found inside office buildings. 

■ In Thurston County, Washington, citizens are receiving a Green Cleaning 
Consumer Education. Local grocery stores promote awareness of least-toxic 
cleaning products via an interactive display set up for two weeks near the 
entrance of the participating store. Shoppers can also receive hand-on 
education through in-store tours that explain the least-toxic products and Green 
Cleaning Kits. The program also teams with local solid waste reduction and 
ground water programs. 16 


16 Ibid. 


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Chapter 6 - Community and Non-Profit Organizations 


Table 6-1. Indoor Air Pollutants 


Pollutant 

Sources 

Possible Health Effects 

Radon 

Earth and rock beneath the home, 
water, and building materials. 

No immediate symptoms. Estimated to well 
contribute to between 7,000 and 30,000 lung 
cancer deaths each year. Smokers are at a 
higher risk of developing radon-induced lung 
cancer. 

Organic Gases 

Household products including 
paints, paint strippers, and other 
solvents, cleansers stored fuels, 
hobby supplies. 

Eye, nose, and throat irritation; headaches, loss 
of coordination, nausea, damage to liver, 
kidney, and central nervous system. Some and 
organics can cause cancer in animals, some are 
suspected or known to cause cancer in humans. 

Formaldehyde 

Pressed wood products (hardwood, 
plywood, paneling, particle board) 
and furniture made from these 
materials. Durable press drapes, 
other textiles, and glues. 

Eye, nose, and throat irritation, wheezing and 
coughing; fatigue; skin rash; severe allergic 
reactions. May cause cancer. May also cause 
other effects listed under “organic gases.” 

Pesticides 

Products used to kill household pests. 
Also products used on lawns and 
gardens that drift or are tracked 
inside the house. 

Irritation to eye, nose, and throat; damage to 
central nervous system and kidney; increased 
risk of cancer. 

Asbestos 

Deteriorating, damaged, or disturbed 
insulation, fireproofing, acoustical 
materials, and floor tiles. 

No immediate symptoms, but long-term risk of 
chest and abdominal cancers and lung diseases. 
Smokers are at higher risk of developing 
asbestos-induced lung cancer. 

Lead 

Lead-based paint, contaminated soil, 
dust, and drinking water. 

Lead affects practically all systems within the 
body. Lead at high levels (above 80 
micrograms per deciliter of blood) can cause 
convulsions, coma, and even death. Lower 
levels can adversely effect the nervous system, 
kidney, and blood cells. 

Tobacco Smoke 

Cigarette, pipe, and cigar smoking. 

Eye, nose, and throat irritation; headaches; 
lung cancer; may contribute to heart disease. 

For children, an increased risk of lower 
respiratory tract infections and ear infections, 
asthma, and decreased lung function. 

Carbon Monoxide 

Unvented kerosene and gas space 
heaters, leaking chimneys and 
furnaces, gas water heaters, wood 
stoves, and fireplaces. Automobile 
exhaust from attached garages. 

At low concentrations, fatigue in healthy 
people and chest pain in people with heart 
conditions. At higher concentrations, impaired 
vision and coordination, headaches dizziness; 
confusion, and nausea. Fatal at high 
concentrations. 

Biological 

Contaminants 

Include bacteria, molds, mildew, 
viruses, animal dander and cat saliva, 
mites, cockroaches, and pollen. 

Allergic reactions and asthma. Infectious 
illnesses such as influenza, measles and dust 
chicken pox. Mold and mildew can release 
disease-causing toxins. 

Source: EPA’s Office of Radiation and Indoor Air 


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Chapter 6 - Community and Non-Profit Organizations 


National Non-profit Organizations 

National organizations play crucial roles in advancing pollution prevention. It has 
been a primary focus for some new organizations and a new role for many estab¬ 
lished groups. Activities include new collaborations, innovative approaches, research, 
and information sharing. Central to the efforts of these groups are the data made 
available via EPA’s Toxics Release Inventory (TRI). Established by the Emergency 
Planning and Community Right-to-Know Act (EPCRA) in 1986, TRI contains data 
on chemicals released from manufacturing facilities in the United States, which pro¬ 
vide communities and non-profit groups with a factual basis for negotiations with 
local industries on measures to reduce waste generation. 17 

Below are a few examples of the efforts of national non-profit groups in the area of 
pollution prevention: 

■ The National Pollution Prevention Roundtable (NPPR) is the largest 
membership organization in the United States dedicated solely to avoiding, 
eliminating, and reducing pollution at the source. Founded in 1985, the 
Roundtable membership consists of pollution prevention professionals at the 
state, local, and tribal government levels with affiliate members from private 
industry, non-profit organizations, trade associations, federal agencies, and 
academic institutions. The Roundtable sponsors twice yearly conferences on 
pollution prevention, which reach a wide audience, in addition to numerous 
workshops, maintenance of the NPPR Network, list serves, and a clearinghouse. 
In August 1995, the Roundtable co-sponsored the first National Tribal Pollution 
Prevention Conference held in Billings, Montana. Sixty-two tribes from 28 
states and Canada attended the workshops and sessions, which provided insight 
into pollution prevention principles and methods. 

Pollution prevention has also been a primary focus for several professional associations. 

■ The American Institute for Pollution Prevention (AIPP) occupies a unique 
niche in pollution prevention as an organization of organizations — its 
members represent 28 trade associations and professional societies across a 
broad spectrum of American industries and professions. Its mission includes 
information dissemination, technology transfer, promoting sound pollution 
prevention policies, and facilitating communications among industry, govern¬ 
ment, non-government organizations, and academia. 

When AIPP was founded in 1989, its original objective was to provide a forum 
to discuss the “hows” and “whys” of pollution prevention. AIPP has developed 
educational materials on pollution prevention for engineering curricula and 
financial analyses of pollution prevention projects, and recently expanded its 
efforts to improve information sharing and promote voluntary prevention 
programs, including Climate Wise. 


17 See the EPA chapter of this Report for a more detailed description of the TRI program. 

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Chapter 6 - Community and Non-Profit Organizations 


■ One seventh of the entire gross national product of the United States is taken 
up by health care products and services. The National Association of 
Physicians for the Environment (NAPE) was created to engage this massive 
institutional and individual professional healthcare apparatus in pollution 
prevention efforts, to promote the understanding that: “Pollution Prevention is 
Disease Prevention.” NAPE focuses on both the health impacts of environ¬ 
ment hazards, and the waste reduction and pollution prevention opportunities 
presented in hospitals and medical practices. NAPE has sponsored confer¬ 
ences on the health impacts of air pollution, and in collaboration with the 
National Wildlife Federation, has developed the Physicians Green Office 
Guide, and the guide A Green Home is a Healthy Home for the public. 

Established government organizations, focused on local community initiatives, have 

found a new role in helping promote prevention among their membership groups. 

■ The National Association of Counties (NACo) is the only national organiza¬ 
tion that represents county governments. Established in 1935, NACo’s goals 
are to improve county government, act as a liaison with other levels of 
government, present the county position on national issues, and assist counties 
in helping their citizens achieve a better quality of life. 

■ The National Association of County and City Health Officials (NACCHO) 
is a non-profit membership organization serving all 3,000 local health 
departments nationwide, in cities, counties, townships, and districts. NACCHO 
provides education, information, research, and technical assistance to local 
health departments. It facilitates partnerships among local, state, and federal 
agencies in order to promote and strengthen public health. 

■ Formally inaugurated in December 1996, the Joint Center for Sustainable 
Communities (JCSC) is sponsored by the National Association of Counties and 
the U.S. Conference of Mayors. The JCSC represents an effort by local elected 
officials to address shared and difficult problems associated with sustainability 
— many of them linked to pollution prevention. Much of the JCSC’s work 
centers around providing conferences and workshops for members, providing a 
clearinghouse of information on prevention and sustainability, and planning 
demonstration projects. 

■ The Center for Neighborhood Technology works with other groups, both 
locally and nationally, to develop sound transportation policies for communities 
and the environment. Its Transportation and Air Quality Program seeks to 
reduce transportation demand through comprehensive transportation manage¬ 
ment and reinvesting in urban neighborhoods. Its activities include land use 
mapping and transit oriented design. 18 


202 


18 Center for Neighborhood Technology Internet Site, (http://www.cnt.org/tsp/tsphome.htm) 






Chapter 6 - Community and Non-Profit Organizations 


■ Renew America is a national non-profit organization working to promote 
environmentally sustainable communities. The organization sponsors confer¬ 
ences and maintains a data base of over 1,600 successful environmental 
programs at the local level. The data base, referred to as the Environmental 
Success Index, is available in print or on-line at http://www.crest.org/ 
renew_america. One important program area for the organization is natural 
resource conservation. 

■ The Institute for Local Self-Reliance (ILSR) helps communities throughout 
the United States and abroad reap the benefits of recycling. ILSR’s advice and 
analysis link community waste management needs with economic development. 
The Institute analyzes local waste streams and develops successful procurement 
and recycling programs. 

Prevention has been the occasion for established environmental groups to take on 

expanded and new roles in collaborative projects. 

■ The impetus for pollution prevention has often been provided by public 
interest groups, including the Environmental Defense Fund (EDF). A decade 
ago, EDF first petitioned EPA to regulate dioxin, the potent poison associated 
with Agent Orange and the evacuation of Times Beach, Missouri. Since then, 
EDF has been instrumental in developing incentives for more efficient energy 
use and reducing the creation of hazardous and solid waste and ozone depleting 
substances. 

This preventive approach is demonstrated through the Pollution Prevention 
Alliance (PPA) and the Great Printers Project. PPA unites EDF and more than 
120 local, state, regional, and tribal environmental organization in the Great 
Lakes region to promote pollution prevention through collaborative workshops 
and local demonstration projects. The Great Printers Project seeks to influence 
factors, usually beyond the control of the average printing business, that can 
constrain business environmental decisions. It focuses on changing factors that 
lead the businesses away from preventing pollution at the source. The project 
especially targets regulatory requirements, customer demands, and access to 
technology and financial resources. 

For example, owners of print shops have been faced with as many as 46 
separate federal reporting requirements that resulted in confusion and non- 
compliance. EDF worked with a team of Great Lakes regulatory and economic 
development agencies, EPA, state and federal technical assistance providers, 
printers, suppliers, and customers to build a consensus for a consolidated 
regulatory system that focuses on reducing hazardous and solid waste. 

■ The Pollution Prevention Pilot Project (4P) brings together experts from 
industry and the environmental community to learn how to save money at the 
facility level via pollution prevention. The 4P is lead by The Natural Re- 


203 







Chapter 6 - Community and Non-Profit Organizations 


sources Defense Council, Amoco Petroleum, The Dow Chemical Company, 
Monsanto Company, Rayonier, and the New Jersey Department of Environ¬ 
mental Protection. The 4P members are working at two chemical manufactur¬ 
ing facilities — a Dow Chemical plant in La Porta, Texas, and a Monsanto 
plant in Pensacola, Florida. Creative ideas for addressing site-specific 
environmental concerns have already begun to show significant cost savings 
and environmental improvement. The 4P is hoping to identify the internal, 
external, and regulatory barriers that discourage facilities from implementing 
pollution prevention measures. The goal of the project is to develop a policy 
to spur the use of innovative economic and environmental ideas to achieve 
pollution prevention at industrial facilities. Both industry and environmental 
groups have recognized the advantages of a cooperative approach. 19 

■ Some non-profit organizations focus on one particular media. Clean Water 
Action and Groundwater Guardian are two such organizations — both 
focusing on protection of the nation’s waterways. Clean Water Action is a 
national grassroots organization that educates citizens on issues affecting their 
communities and urges them to actively participate in the political process to 
affect change on environmental issues. While pollution prevention is not the 
group’s only focus, it is an important aspect of its education and outreach 
efforts. The Groundwater Guardian program supports, recognizes, and connects 
communities for the protection their groundwater. The program is community 
driven and process oriented. Once again, pollution prevention is an important 
aspect of the program, along with monitoring activities. 

The TRI has helped non-profit organizations promote prevention by providing infor¬ 
mation to communities. 

■ OMB/Watch (the Office of Management and Budget) is a non-profit group that 
advocates the public’s right-to-know and greater government accountability. 
OMB/Watch and the Unison Institute, a center for computer systems and 
software technology in the public interest, operate the Right-to-Know Network 
(RTK NET), a free online computer telecommunications system that provides 
access to the latest national data bases including thecomplete TRI data bases. 
RTK NET is currently funded by several EPA program offices, with additional 
funding by other federal agencies and private foundations. 

Thirteen national environmental data bases are currently available on RTK NET 
and are integrated into a single master data base to support cross indexing and 
multimedia research. Four of the more important data bases related to pollution 
prevention are the following: 


204 


19 President’s Council on Sustainable Development. Council Report. Washington, DC (1995). The 
Report is available on the Internet at http://www.whitehouse.gov/WH/EOP/pcsd. 




Chapter 6 - Community and Non-Profit Organizations 


• BRS (Biennial Reporting System) 

• CUS (TSCA Inventory of Chemical Production Data Base) 

• TRI (Toxics Release Inventory) 

• ROADMAPS (health information regarding TRI chemicals) 

Users can access RTK NET by modem or via the Internet (http://www.rtk.net). 

■ The Working Group on Community Right-to-Know is a coalition of local, 
state, and national environmental groups concerned with the public’s right-to- 
know about hidden chemical hazards and toxic pollution. The coalition is 
committed to public education and outreach in the areas of pollution preven¬ 
tion, chemical accident prevention, and information reform. 20 

■ INFORM, founded in 1974, is a non-profit environmental research organiza¬ 
tion that seeks practical solutions to problems in chemical hazard prevention, 
solid waste management, alternative vehicle fuels, and agricultural water 
conservation. Through its reports, testimony, and other efforts, INFORM has 
been promoting source reduction to governments and industry since 1982. For 
example, INFORM developed several research documents and guides for 
citizens concerned about hazardous waste. Preventing Industrial Toxic 
Hazards: A Guide for Communities introduces the concepts behind pollution 
prevention, summarizes applicable laws, and explains how communities can 
find out about emissions from local industrial facilities. 21 

Today, INFORM’s research has broadened to study not only the processes 
employed to manufacture products, but also chemical use and product design. 

INFORM not only identifies pollution prevention possbilities for others, it also 
integrates the concept into its own operations. INFORM has turned its own 
office into a “green space,” using an interior design strategy that includes open 
design, energy efficient lighting, insulated duct work, and less toxic materials. 
In cooperation with architects Croxton Collaborative and building owner 
Silverstein Properties, INFORM renovated its new office space for $38 per 
square foot, 27 percent less than conventional office construction costs in New 
York City, where it is located. The new office was not only more cost effective 
to renovate, but will also save money over the lifetime of the building. 22 

Communities and non-profit organizations are often left out of the pollution preven¬ 
tion equation, but unjustifiably so. National non-profit organizations have been in¬ 
strumental in introducing many environmental concepts, including pollution preven¬ 
tion, to the public and are leading advocates for change at the local, state, federal, and 


20 Interview with Paul Orum, Working Group for Community Right to Know (May 1995). 

21 Interview with Mia Fienemann, INFORM (May 1995). 

i 22 “Building Design,” Pollution Prevention News (July-August 1995). 


205 






Chapter 6 - Community and Non-Profit Organizations 


global levels. Many community-based organizations have spearheaded progress in 
environmental justice and right-to-know legislation. Communities facing previously 
intractable issues of transportation, land use, economic development, and environ¬ 
mental justice are finding that pollution prevention offers an array of solutions that 
tackle the problems at their source. This chapter has highlighted several local initia¬ 
tives for affecting change that demonstrate both the vitality of the organizations in¬ 
volved and the multiplicity of pollution prevention opportunities and challenges. 


206 





Chapter 6 - Guest Commentary 


Public Information for Pollution Prevention 
by 

Paul Orum 

Working Group on Community Right-to-Know 
Washington, DC 


To prevent pollution, people need adequate information. With adequate information, communities can demand 
accountability from industry and government. Pollution prevention requires well-informed interactions at many 
levels of society. But while information to track and promote prevention should underlie all of these interactions, 
for the most part, it doesn’t. Without basic chemical use and emissions information, we cannot expect to see 
much pollution prevention. 

EPA information doesn’t include most pollution sources. It doesn’t provide a full picture of accidental releases. It 
doesn’t usually show why pollution occurs or what technological alternatives exist. It doesn’t indicate the health 
hazards of most chemicals. And it doesn’t enable people to readily form environmental profiles of industrial 
facilities. 

Different pollution control laws regulate different chemicals; use different units of measure; cover different sets 
of facilities; address different environmental media; span different reporting periods; inform different govern¬ 
ment offices; and, store information in different files and computers with different rules for public access. As a 
result, both regulators and the public make uninformed decisions. 

Many environmental laws recognize the value of public participation. Non-profit groups serve as catalysts, they 
spotlight problems and propose solutions. Citizens have a legitimate and productive role to play. Public disclo¬ 
sure of Toxics Release Inventory (TRI) data, for example, has encouraged considerable pollution prevention and 
control. More complete information would extend similar benefits across the board, bringing in more commu¬ 
nities, companies, and activities. 

Of course providing information does not by itself assure progress in pollution prevention. Many other factors 
are more limiting than the lack of information. These include feelings of fear and powerlessness in communi¬ 
ties; lack of organizational and institutional support, and opposition from pollution control and chemical manufac¬ 
turing industries. To stimulate prevention, people need well-organized communities, reliable information, techni¬ 
cal assistance, appropriate opportunities to intervene, sound definitions, and most importantly, support from the 
entire regulatory system. Below are three types of prevention information that can help fill the gaps. 

1) People need basic prevention information. Ten years ago, the Office of Technology Assessment reported 
that data collected under pollution control laws did little to help companies assess where and why they generate 
toxic waste. The information was incomplete, inconsistent, and inaccessible. Separate systems created informa¬ 
tion barriers within firms as well as government. In various ways these laws encouraged costly pollution control 
rather than prevention. Unfortunately, basic information for prevention remains limited today. 

The 1986 TRI law gave many communities ready access for the first time to pollution data from corporate files and 
computers. The 1990 Pollution Prevention Act added how much waste TRI companies burn, treat, and recycle. 
More source reduction means less toxic waste, less worker and community exposure, and less potential for 



207 













Chapter 6 - Guest Commentary 


contamination. For example, hazardous waste recycling is associated with over 100 Superfund sites. But TRI 
remains limited, and EPA is adding more chemicals, industries, and materials accounting data for prevention. 
Materials accounting tracks the basic flow of chemicals through the facility and helps reveal prevention oppor¬ 
tunities. 

Advocates have presented a long list of advantages provided by such data. A basic materials accounting helps 
people to: tell where chemicals go (as waste or in product); identify low cost prevention opportunities; measure 
chemical use; conduct full cost accounting; conduct life cycle assessment; form a baseline for planning; validate 
emissions data; improve public understanding; improve chemical management capacity; assess worker expo¬ 
sure; establish formal employee prevention programs; encourage technology transfer; and obtain the “whole 
picture information” needed for pollution prevention. All of these activities require effective interactions be¬ 
tween well-informed people. Expanding TRI is just a start. 

2) People need integrated information. Information collected under environmental laws is disjointed. Sepa¬ 
rate laws enacted over the past 25 years cover different environmental media, standards, and programs. As a 
result, EPA cannot readily profile a facility’s environmental performance or link data across more than a dozen 
program offices — despite spending over $300 million each year on environmental information. 

Many people see Internet access to environmental data as a new frontier of activism. However, such access also 
transfers the underlying problems of disjointed single-media information to a broader public. To integrate the 
underlying information, EPA is adopting common sense elements called “key identifiers” that enable people to 
obtain information from across EPA’s data collections. Common key identifiers and examples of their applica¬ 
tion are: 

a) A community group easily finds out what environmental information a local factory reports (facility ID 
number). 

b) A student maps community pollution sites, populations, and sensitive environments on a home computer 
(accurate latitude and longitude). 

c) A company environmental manager readily determines what regulatory requirements govern the use of a 
particular chemical (regulated substance). 

d) A state prevention program locates cleaner technologies for a particular industry through an EPA 
clearinghouse (industrial sector, SIC code). 

e) An emergency responder identifies local firms that use a dangerous chemical and assesses where it would 
go if accidentally released (chemical name and CAS number). 

f) A citizens’ group quickly finds out if a firm has been a “bad neighbor” or “good neighbor” at its operations 
elsewhere (parent company tax ID number). 

With these and other identifiers, people can also link toxicological data, worker and public health data sets and 
registries, local human resources organizations, and other community health information. Integrating informa¬ 
tion around key identifiers will also help EPA to unify permitting, inspections, training, and reporting — critical 
steps for pollution prevention. However, more is needed. 

3) People need information on solutions, not just more study of problems. Risk information alone provides 
a poor basis to address environmental problems and form public partnerships. Risk assessments study prob- 


208 



Chapter 6 - Guest Commentary 


lems , but people also need information on technological alternatives — on solutions. These approaches require 
different skills, methods, and resources. Too often, risk assessments become experts’ debates in which uncertain¬ 
ties turn into political opportunities for delay. Not surprisingly, many efforts to roll back environmental laws have 
revolved around risk assessment. Yet too few environmental laws produce useful information on solutions. For 
example, new EPA regulations require companies to disclose potential spills, fires, and explosions as part of larger 
Risk Management Plans. However, EPA did not require firms to assess inherently safer technologies that reduce 
or eliminate hazards. 

Additional information barriers limit prevention. Independent expert oversight and public reports on chemical 
accidents are fundamental to community right-to-know, but without funding for the National Chemical Safety 
Board, communities are not getting this information. People need health and safety information on chemicals, 
but trade secret claims impede access to Toxic Substances Control Act data. People need information to enforce 
pollution laws, but proposed Clean Air Act monitoring won’t enable people to track compliance. People need an 
environment that supports technology transfer, but audit privilege laws in some states impede the free flow of 
information on prevention technologies. Consumers need information on chemicals in products, but pesticide 
product labels fail to honor the public’s right-to-know. Directly or indirectly, all of these information barriers 
impede prevention. 

Efforts to roll back environmental laws consistently target public information on environmental hazards and 
compliance. By restricting information, these efforts would limit the interactions needed at all levels of society 
to prevent pollution. Yet these rollbacks, if successful, can only increase public demands to hold government 
and industry accountable. Rather than rollbacks, we need to start with full disclosure. 




Chapter 6 - Guest Commentary 



Community Challenges 

by 

Mary Rosso 

President 

Maryland Waste Coalition 
Glen Burnie, Maryland 


In my opinion, the biggest challenges that communities face in promoting local pollution prevention can be 
summed up in two words. They are: RESOURCES and EDUCATION. The communities need both of these if 
they are to implement any program aimed at pollution prevention, waste reduction, safe alternatives, etc. I am 
enthusiastic about EPA’s efforts to promote community-based environmental protection because it has never 
been done before on a large scale, and certainly not done in a “hands on” manner in the heart of the community. 
The only way a good program can succeed is if all parties (local, state, and federal) participate so that all entities 
are operating at the same time, providing non-conflicting information. Here, at the Maryland Waste Coalition, 
we strive to achieve such uniform participation. 

In 1980, with a grant from the Environmental Protection Agency, the Maryland Waste Coalition was created to 
educate local communities about hazardous waste issues. Since that time, the Coalition has continued as a volunteer 
organization, and has expanded its focus to include all environmental issues. We are still heavily involved with 
community environmental issues, and operate at the local, state, and federal level. For example, we are actively 
involved in EPA’s Project XL. In addition to community education, the coalition works directly with industry. I have 
been involved with the coalition since its inception, and have watched our partnership roles with industry evolve from 
adversarial to cooperative. We act as a watchdog group, supporting pollution prevention legislation, and being in¬ 
volved with regulatory noncompliance by industry, but also assisting “good neighbors” with expediting their permitting. 

The Coalition is currently working on a new partnership program in the Baltimore City/Anne Arundel County corri¬ 
dor that will involve the Federal, state, and local governments. This area is heavily populated by the chemical industry, 
so waste disposal issues such as incinerators, landfills and Superfund sites are a high priority. It is too early to tell how 
effective the new program will be, but it has gotten off to an exciting start. We had a great kick-off meeting in August 
1996, with over 170 people, including representatives from at least 50 industries, attending. Out of those 170, 49 
participants agreed to work on committees. 

We are now breaking into sub-committees that will accumulate information and start implementing priority concerns. 
These concerns address the major problems we feel can be reasonably worked on provided that EPA, the Maryland 
Department of the Environment, and local governments help us with the factual data and give us guidance in its proper 
use. These subcommittees will address a wide variety of environmental issues such as: 1) health effects; 2) air quality; 
3) stormwater management, parks, recreation, and open spaces water quality (including NPDES permits); 4) economics 
and the environment; and 5) housing and trash cleanup. These subcommittees will be headed by co-chairs, one repre¬ 
senting the local community, and one representing industry. 

In the future, we hope that EPA and other government and non-govemment organizations can assist the Coalition. 
Assistance can take the form of grants or technical assistance such as expertise in areas such as permitting. With access 
to knowledgeable scientists and regulatory experts, the Maryland Waste Coalition can help make the Maryland environ¬ 
ment better for us all. 


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Chapter 6 - Guest Commentary 


Local Government: An Important Pollution 
Prevention Partner 

by 

Naomi Friedman 

Project Coordinator for Solid Waste and Pollution Prevention Projects 
National Association of Counties 
Washington, DC 


and 

Karen Troccoli, MPH 

Project Manager for Environmental Health Programs and Policies 
National Association of County and City Health Officials 
Washington, DC 

During the past several years, an important change has taken place in national strategies to protect the environ¬ 
ment and human health. By increasing the efficiency with which we use raw materials and by substituting 
benign products for more hazardous ones, we have demonstrated success in preventing or reducing pollutants 
that infiltrate our air, water, and land. This trend toward front-end, pollution prevention strategies has been 
promoted not only by federal and state governments and a growing number of businesses, but by local govern¬ 
ments as well. Indeed, because of their unique position in the community, local governments have been able to 
spur pollution prevention activities that otherwise may not have been possible. 

Historically, citizens’ expectations for a clean and healthy community have been met through basic services, 
including clean-up, treatment, and disposal, provided by local government. Although diminishing resources, 
coupled with increasing mandates, threaten to leave communities with little time for innovative, voluntary 
prevention efforts, local pollution prevention initiatives continue to flourish. Cities, counties, towns, and town¬ 
ships are finding that pollution prevention is a fundamental and less costly way to protect the environment and 
public health. 

Strengths of the Community-based Approach 

Implementing pollution prevention programs at the local level makes sense for many reasons. Local govern¬ 
ment is on the “front line” where the impact of pollution on neighborhoods and the people who live in them is 
most apparent. Local agencies are notified first when a local environmental problem is detected. If a drinking 
water supply shows an elevated level of a pollutant, it is the local health department that is barraged by calls of 
inquiry and concern. When an illegal dump site is discovered, residents will report the problem to the local law 
enforcement agency, the department of public works, or their local elected officials. And, when a household 
fails to receive collection of trash or recyclables on the designated day, residents will call their city or county 
government to complain. As a result, local governments are highly motivated to reduce the environmental 
problems to which their residents are exposed and ensure the long term safety of their community. 



211 













Chapter 6 - Guest Commentary 


The physical proximity of local government to citizens and businesses makes them an ideal disseminator of pollu¬ 
tion prevention information. Local officials, such as sewage pretreatment inspectors, fire inspectors, permitting 
and licensing officers, health officials, zoning and planning board members, and economic development officers 
interface with the community on a routine basis. Pollution prevention education can be incorporated into these 
responsibilities. Moreover, in their capacity as building owners and managers, fleet operators, and procurement 
agents, city and county governments can incorporate prevention and conservation techniques into internal opera¬ 
tions and serve as models to the community. 

Because pollution prevention spans the domain of diverse agencies and segments of the community, most local 
pollution prevention efforts are collaborative in nature. Numerous agencies are involved in these efforts, ranging 
from the local health department to the department of public works. Another incentive for cooperation is limited 
resources — funding to hire “pollution prevention staff’ is uncommon, forcing counties and cities to shift 
existing staff within health departments, public works divisions, environmental compliance bureaus, solid waste 
offices, economic development offices, and/or general administrative offices into pollution prevention roles. 
Although a few communities have managed to secure additional funds to support a coordinator to oversee com¬ 
munity-wide projects, most of them try to incorporate the pollution prevention ethic into existing city/county 
programs. 

Local health departments have played a particularly important role in initiating and/or maintaining pollution 
prevention programs. Local health departments have historically focused on primary prevention in their ongoing 
efforts to protect the public from risks of exposures to harmful substances and maintaining clean and safe air, 
water, and facilities. These are also the essential elements of pollution prevention. 

On the local level, there are not only increased opportunities for agencies to integrate functionsand form part¬ 
nerships, there is a great opportunity for government to form partnerships with private organizations, such as 
universities, trade organizations, chambers of commerce, community groups, and other entities with a common 
interest in pollution prevention. Such collaborations benefit all participants because they increase exposure, 
build credibility, and provide a forum for sharing ideas. 

Pollution Prevention on the Front Lines 

In recent years, cities and counties have stepped forward as leaders in pollution prevention and their efforts are 
gaining attention. These pioneering communities, such as Dade County, Florida; Newark, New Jersey; Cincinnati, 
Ohio; Santa Clara County, California; Erie County, New York; Thurston County, Washington; San Diego, Califor¬ 
nia; and Olmsted County, Minnesota, span the country, representing urban, suburban, and rural locales. Collec¬ 
tively, these communities have provided thousands of businesses, households, and civic organizations with pollu¬ 
tion prevention information and technical assistance. 

Many local governments’ pollution prevention programs focus on delivering information on process efficiencies, 
material substitutions, and best management practices to small and medium sized companies. Local agencies 
target community businesses that use or emit chemicals that are a particular problem in the locality or region, 
that are in noncompliance with environmental regulations, and/or that are receptive to new and innovative ideas. 
These industries typically include: automotive repair and refinishing; print shops; the construction and building 
industry; photography finishers; and dry cleaners. Some communities put a specific local twist on their pro¬ 
grams, such as Broward County, Florida, which is educating the marina and boating industry about best manage¬ 
ment practices; and Phoenix, Arizona, which has targeted dentists to reduce mercury discharges into the wastewa¬ 
ter treatment facility. 


212 






Chapter 6 - Guest Commentary 


) 




City and county governments deliver pollution prevention information to the community using a variety of local 
networks including: the local press, pollution prevention workshops or seminars, pollution prevention mail¬ 
ings, hand-delivered information to targeted companies, and on-site pollution prevention audits. Although 
pollution prevention techniques may ultimately help a business meet environmental requirements, communi¬ 
ties generally keep participation in these efforts voluntary, as businesses are more comfortable sharing informa¬ 
tion with government officials when the relationship is nonregulatory. Some communities, however, have 
made pollution prevention requirements part of an enforcement or consent agreement. 


Some municipalities and counties have chosen to focus prevention efforts on nonpoint sources of pollution by 
helping residents better maintain septic systems and reducing urban run-off to delicate watersheds, while other 
local governments have examined their own purchasing habits and use of hazardous chemicals and have tar¬ 
geted internal operations for pollution prevention. Local agencies also target consumers with education cam¬ 
paigns that stress the importance of product substitution and household hazardous waste usage and disposal 
issues. 


Expanding Local Government’s Role in Pollution Prevention 

Local governments have demonstrated considerable success in incorporating pollution prevention into their 
community initiatives. They have documented significant dollar savings and tonnages of pollution avoided as 
a result of businesses adopting recommended pollution prevention strategies. Many counties and cities have 
also implemented innovative public education campaigns that have helped citizens, businesses, and organiza¬ 
tions to understand why and how they can take steps to reduce the amount of waste they generate. Finally, local 
health departments are making great strides in advocating the importance of pollution prevention in regard to 
its connection to human health. 

Despite these successes, it is clear that local government could do even more, given adequate support — namely, 
monetary support, technical support, and political support. State and/or federal funding has enabled many 
communities to launch programs they otherwise would not have been able to undertake. The infusion of seed 
money encourages local officials to take more program risks and justifies implementation of pollution preven¬ 
tion efforts that are not required by federal or state law. In many cases, pilot initiatives become self-sustaining 
and an integral part of a community’s environmental and public health programs. County and city agencies 
have made the most of existing funds by incorporating pollution prevention into ongoing activities and forming 
partnerships with other organizations to consolidate efforts and leverage additional funding. However, in¬ 
creased availability of federal and state funds for local governments’ pollution prevention activities is needed. 

Communities also report that technical support and encouragement from the federal and state government 
spurred their interest in pollution prevention. Larimer County, Colorado, in the report of its Pollution Prevention 
Technical Advisory Group, states, “although federal and state government assert the importance of pollution 
prevention, local government and businesses lack the information and assistance necessary to make the transition 
from traditional, end-of-pipe environmental protection mechanisms to pollution prevention.’’ Local governments 
need informational materials such as fact sheets, fliers, and brochures for citizens and businesses. They also can 
use model ordinances and examples of pollution prevention strategies that have been effective in other communi¬ 
ties. While localities often depend upon federal and state agencies for these materials, networks of local agencies 
working on pollution prevention, such as the Local Government Workgroup of the National Pollution Prevention 
Roundtable, and associations with whom communities have a trusting relationship, provide effective forums for 


I 


213 




Chapter 6 - Guest Commentary 


the exchange of information, partnership development, and other technical support. For example, our two organi¬ 
zations, with funding from the U.S. EPA, and in collaboration with the U.S. Conference of Mayors and the Na¬ 
tional Pollution Prevention Roundtable, recently published a compendium of 19 model city and county pollution 
prevention programs that has been widely distributed throughout the country. 

Garnering political support within the community for pollution prevention is important, given the competing 
priorities that challenge local policy makers. Pollution prevention, like other preventive measures, is a long-term 
investment. That means elected officials may not witness the benefits of a pollution prevention initiative within 
their political term. For these reasons, policy makers need additional support and encouragement to make pollu¬ 
tion prevention a priority. The more that pollution prevention is promoted by the federal government, 
stategovernment, private organizations and citizens, the more likely it is that local policy makers will join the 
bandwagon and support such initiatives in their communities. 

With the unique responsibilities of setting local policies, encouraging local development and protecting the 
public’s health, local government is positioned to play a critical role in pollution prevention. Increasing devolu¬ 
tion of responsibility from the federal to the state and local level, and greater regulatory flexibility, means greater 
opportunities for local governments to take on leadership roles and invest in pollution prevention efforts that 
will help achieve better environmental protection results for their communities. Local government has been a 
crucial force in creating the momentum around pollution prevention and it promises to build on that momentum 
and on its own accomplishments in the years to come. 


214 




Chapter Seven 


Measuring Pollution 
Prevention 


■ The Emerging Framework for 
Measuring Prevention 

■ Measuring Program Effectiveness in 
States and Communities 

■ Measuring Pollution Prevented 

■ Other Measures for Pollution Prevention 

■ Guest Comments: 

Ken Geiser and Elizabeth Harriman, 
Toxics Use Reduction Institute 
















Chapter 7 - Measuring Pollution Prevention 


216 







Chapter 7 - Measuring Pollution Prevention 


Introduction 

The chapter discusses the two key aspects of measuring pollution prevention results: 
assessing program effectiveness and determining pollution reductions. Evaluations 
of pollution prevention program effectiveness have been undertaken in the last few 
years by some of the more established state programs. Questions asked are typical of 
program evaluations in other fields: Are we reaching the right people? Are informa¬ 
tion and technologies being disseminated and used? Are program personnel ad¬ 
equately trained to deal with the program’s clientele? How best should scarce re¬ 
sources be deployed to achieve results? This chapter reports on the results of several 
surveys conducted by Massachusetts, Iowa, New Jersey, and other states. 

Determining pollution reductions, i.e., measuring the amount of pollution prevented, 
has always been an elusive goal. Traditional environmental monitoring of pollution 
depended largely on the proper technical skills and equipment. For years, EPA, state 
agencies, and companies measured only what came out of a pipe and into a single 
environmental medium like air or water. The technical challenge was to ensure that 
the end-of-pipe figures were accurate. 

Measuring pollution that is prevented is much more difficult. With pollution preven¬ 
tion come industrial process changes, changes in the mix of chemicals used, changes 
in the products manufactured, and changes in production volume and markets. Deter¬ 
mining how much pollution has been prevented and where in the multiple points in the 
industrial process such prevention occurred is a difficult task. 

Nevertheless, significant progress has been made over the last five years in refining 
the measurement of pollution prevention, in studying the effectiveness of different 
types of pollution prevention programs, and in developing appropriate indicators of 
success in pollution prevention. Much remains to be done, and pressures on EPA and 
state governments to strengthen their measurement efforts have received new urgency 
from legislation and agreements, discussed below. This chapter explores why mea¬ 
surements of pollution prevention are important, discusses several of the measures 
commonly used, reports on the results of pollution prevention program evaluation stud¬ 
ies, and outlines future directions and challenges in this area. 

Tlie Emerging Framework for Measuring 
Prevention 

One impetus for industrial facilities to measure the amount of pollution they create is 
obvious — pollution is waste, and waste is lost opportunity for profit. Businesses 
also measure in order to find the most efficient ways to comply with environmental 
regulations and to reduce the risks to workers’ health and the potential for future 
environmental liabilities. 


217 







Chapter 7 - Measuring Pollution Prevention 


For government the simple answer to the question of “why measure?” is that until we 
know what impact prevention is having on the environment, it is impossible to judge 
the success of pollution prevention programs and to determine if and how they should 
be changed. Today the pressures to measure outcomes are greater than ever, as the 
federal government must comply with the Government Performance and Results Act 
of 1993 (GPRA) and state environmental leaders have, in exchange for EPA’s willing¬ 
ness to grant them flexibility in managing their programs, agreed to focus on measur¬ 
ing outcomes through the National Environmental Performance Partnership System 
(NEPPS). 

The Government Performance and Results Act 

GPRA (also known as "The Results Act") requires all federal agencies to: 

■ develop strategic plans prior to FY 1998 

■ prepare annual plans setting performance goals beginning with FY 1999 

■ report annually on actual performance compared to goals (the first report is 
due in March 2000) 

The intent of this legislation is to place much greater emphasis on federal program 
execution — on outputs, outcomes, and results rather than inputs, program defini¬ 
tion, and policy formation. Federal program managers will need to shift their focus 
away from activity-based measures of program performance and give greater attention 
to determining how well programs are meeting their objectives and what is being ac¬ 
complished. 

Generally, GPRA should improve the effectiveness and efficiency of federal programs, 
activities, and services. The heightened focus on performance should spur better per¬ 
formance. While reduced federal spending is not the stated purpose of this legislation, 
GPRA should lead to more effective expenditures as ineffective programs or activities 
are either improved or discontinued. 

With respect to pollution prevention, EPA will need to increase its efforts in assess¬ 
ing the effectiveness of pollution prevention programs. States and companies that 
receive federal funding for pollution prevention activities should expect to be held 
more accountable for demonstrating the success of their programs. Performance 
levels will be tied to spending levels. 

The National Environmental Performance Partnership System 

NEPPS, signed by the EPA Administrator and state environmental program leaders on 
May 17, 1995, is designed to give strong state programs more leeway to set environ¬ 
mental priorities, design new strategies, and manage their own programs, while con¬ 
centrating EPA oversight and technical assistance on weaker programs. The major 
components of this agreement include increased use of environmental goals and indi¬ 
cators, state assessments of environmental program performance, environmental per- 


218 



Chapter 7 - Measuring Pollution Prevention 


formance agreements, and increased public involvement. This system envisions a 
trend toward state program self-management and flexibility, while improving environ¬ 
mental and programmatic accountability to Congress and the public. 

A variety of measures will be used to gauge progress under NEPPS. Each state and its 
EPA regional office will agree on the set of measures that the state or EPA will collect 
and report during the year. There are three basic kinds of measures being used in 
tracking the progress of environmental programs: (1) environmental indicators, (2) 
“business” performance measures, and (3) program performance measures. Across all 
measures there are also two general classes of measures: (1) “outcome” measures, 
which show results in the environment or changes in behavior in the regulated commu¬ 
nity, and (2) “activity” measures, which track the various kinds of work done to achieve 
the desired outcome. The states and EPA are making a determined effort to focus on 
“outcomes” as much as possible, while tracking essential activities for internal man¬ 
agement purposes. 

Environmental indicators are viewed as the best, if long-term, way to measure mean¬ 
ingful progress in improving human health and the environment. All states partici¬ 
pating in the new system are expected to use these measures to the fullest as a way of 
focusing program priorities on desired outcomes, and as a useful method of commu¬ 
nicating results to the public. These indicators are expected to add a new and impor¬ 
tant dimension by helping to articulate long-term objectives and by showing the 
extent to which EPA and the states are making progress against those objectives. 

Business performance measures are intended to capture behavior in the regulated com¬ 
munity as they take actions to prevent or reduce health and/or environmental risks. In 
a sense, these are nearer term outcomes that can be measured by environmental agen¬ 
cies to gauge whether programs are having the desired effect. Some enforcement and 
compliance measures, such as compliance rates for individual businesses or industrial 
sectors, fall into this category. 

Program performance measures are those outcomes or activities identified by each 
program that best reflect whether a program is being implemented as designed. In 
the past, these have been heavily weighted toward activity measures. Although it is 
recognized that there will always be a need for activity measures, EPA and the states 
are trying to strike a better balance between outcome and activity measures under the 
new system. 

As part of the May 17 Agreement, EPA also agreed to “develop a limited number of 
program and multimedia performance measures on which each state will report.” In 
fulfillment of that commitment, each Assistant Administrator established a reduced 
set of program performance measures to pilot during FY 1996. These “core program 
performance measures” are the base minimum programmatic measures for regions and 
states to use in negotiating Environmental Performance Agreements. These measures 
applied to all participating pilot states for FY1996. Environmental indicators will be 
added to this core set of program measures. Where states feel they have more appro¬ 
priate measures, these measures can be added or substituted. 


219 


Chapter 7 - Measuring Pollution Prevention 


Program 

Effectiveness 

Measures: 

■ Program 
Development 

■ Core Program 
Activity 

■ Outcome Measures 

■ Results Measures 

■ Goals Achievement 


Measuring Program Effectiveness in States 
and Communities 

In this chapter, we discuss two ways to approach pollution prevention measures: mea¬ 
suring program effectiveness and measuring pollution reductions. Program effective¬ 
ness measures commonly are used by federal and state agencies to assess the overall 
impact of pollution prevention programs. Due to the challenges associated with deter¬ 
mining overall statewide pollution prevention progress, many states have focused ini¬ 
tially on measuring the success of specific state pollution prevention program compo¬ 
nents. In both cases, specific measures of pollution reductions achieved by imple¬ 
menting prevention programs are useful. 

Measuring the Effectiveness of Pollution Prevention Programs 

Program effectiveness can be measured in a number of ways. The most straightfor¬ 
ward are program development measures, answers to questions like, “How many states 
are implementing pollution prevention programs?” Beyond these simplistic measures 
are attempts to measure core program activity; programs might begin to ask questions 
like, “How many multi-media compliance inspections have we completed?” As pro¬ 
grams mature, they might progress to asking outcome measure questions like, “What 
is the percentage of companies in a specific industry sector practicing prevention?” 
The next step would be to count result measures by asking, “How much cleaner is the 
air (or water or land) due to prevention in a particular industry sector targeting a par¬ 
ticular set of chemicals?” And, finally, the ultimate goal of program effectiveness 
measurement is being able to answer specific goals achievement questions like, “What 
percentage of streams meet environmental quality criteria?” or “What is the total risk 
reduction to children from preventing exposure to chemical X?” 

Measuring the Effectiveness of State Pollution Prevention Program 
Components 

Many state legislatures have established statewide goals for reductions in waste gen¬ 
eration or toxics use — generally in conjunction with a pollution prevention facility 
planning requirement. In a number of these states, comprehensive measures of reduc¬ 
tion in generation of wastes or use of toxic materials have been developed to evaluate 
the progress of the state’s pollution prevention program effort with respect to regula¬ 
tory targets. However, evaluating the success of reaching this type of broad program 
goal is complex. Developing comparable measures that will allow such aggregation of 
data at the state level involves a variety of issues that have been dealt with in different 
ways by different states. For example, Massachusetts, which routinely collects data for 
materials accounting, was able to establish an aggregate index. In contrast, Washington, 
which lacks use and product data, chose gross business income as a surrogate index. Due 
to the many technical hurdles that must be overcome to obtain meaningful measures of 
overall statewide pollution prevention progress, many states have focused initially on 
measuring the success of specific state pollution prevention program components. 


220 





Chapter 7 - Measuring Pollution Prevention 


States, as well as independent research organizations, are determining the extent to 
which specific state pollution prevention program components are resulting in actual 
implementation of pollution prevention by facilities. To measure the benefits of state 
pollution prevention programs, evaluators are asking questions like: 

■ Is there a link between the state pollution prevention program elements and 
the pollution prevention measures being taken by the facilities? 

■ For technical services available from the state (e.g., on-site pollution preven¬ 
tion technical assistance, support for research, etc.), is there awareness among 
potential users of the availability of the services? 

■ How valuable or effective is a particular pollution prevention program compo¬ 
nent in causing facilities to implement pollution prevention measures? 

■ How can what we learn about program effectiveness be used to modify compo¬ 
nents of prevention programs so that they can lead to the development of more 
outcome-oriented pollution prevention measures by facilities? 

Some evaluation studies isolate and measure particular aspects of these issues, while 
others try to link measurement elements together to gain a more comprehensive pic¬ 
ture. Typical measurement methods, which can be used individually or in combina¬ 
tion, include: analysis of records, reports, and plans; surveys or in-depth interviews 
(either broadly covering the universe of relevant facilities, or narrowly focused on 
recipients of specific services); focus groups; and case studies. The examples below 
further illustrate some of the approaches and issues in program evaluation. 

Facility Planning Evaluations 

New Jersey’s Department of Environmental Protection (DEP) has undertaken several 
reviews of its pollution prevention facility planning requirement, from the standpoints 
of both effectiveness and benefit to the facilities. Through review and statistical analysis 
of information in facility pollution prevention plans and information provided by the 
facilities about the steps they had taken, DEP developed a summary of some of the 
initial program results as well as of the attitudes of businesses toward the planning 
requirement. 1 

The findings included information on projected trends in chemical use and non-prod¬ 
uct output generation, the processes and chemicals with the highest reduction percent¬ 
age, and the relationship between previous planning experience and facility size and 
the scope of present objectives. For example, DEP found that 75 percent of the facili¬ 
ties had reduction goals greater than zero, and facilities that had undertaken previ- 


'Three sources were used to obtain this information: (1) New Jersey Office of Pollution Prevention. 
Early Findings of the Pollution Prevention Program (June 1995). Department of Environmental 
Protection, Trenton, New Jersey. (2) Hampshire Research Associates. Evaluation of the Effectiveness 
of Pollution Prevention Planning in New Jersey: A Program-Based Evaluation (May 1996). 
Alexandria, Virginia. (3) New Jersey Office of Pollution Prevention. Industrial Pollution Prevention 
Trends in New Jersey (December 1996). Department of Environmental Protection, Trenton, New 
Jersey. 


221 





Chapter 7 - Measuring Pollution Prevention 


ous planning efforts were likely to have more ambitious targets and better plans than 
other facilities. In addition, the facilities themselves confirmed that the planning 
process was beneficial: 74 percent of facilities thought the planning process worth¬ 
while based on cost savings, reduced regulation, or other factors; two-thirds of the 
facilities indicated that some or all of their reduction projects were the result of the 
facility planning process. 

Washington’s Department of Ecology carried out a survey to determine: (1) the 
extent to which facility plans were leading to identification of pollution preven¬ 
tion opportunities; (2) the extent to which those opportunities were the result of 
the state’s facility planning process; and (3) general attitudes toward the facility 
planning requirement on the part of industry. 2 A questionnaire was sent to 393 
facilities, and 185 responded. In addition, in-depth telephone interviews were 
conducted with 13 facilities, and 12 facilities participated in focus groups. The 
study results included the following: 

■ Of the facilities surveyed, 96 percent identified in their plans, and were cur¬ 
rently implementing, pollution prevention opportunities. In the interviews, over 
50 percent said that the major opportunities had been decided upon or initiated 
before the planning process, though the process may in some cases have 
provided an additional push. 

■ The majority of facilities felt that they had already identified the major reduc¬ 
tion opportunities, although minor opportunities might still exist. 

■ Many facilities objected to the more detailed quantification requirements of the 
planning process; sophisticated facilities, however, tended to find the planning 
requirement a paper exercise less detailed than internal management systems. 

■ Facilities had a very positive response to the Department of Ecology’s technical 
support for the planning process (i.e., seminars, telephone support, on-site 
assistance). 

Two studies have looked at facility planning in Massachusetts, using different survey- 
and interview-based techniques. In the first study, the Massachusetts Department of 
Environmental Protection (DEP) carried out inspections at 59 firms to determine: (1) 
whether facilities had met the planning requirement and (2) whether facilities regarded 
the planning exercise as useful. Of those inspected, 77 percent indicated that the plan¬ 
ning process was useful, and 92 percent stated that they planned to implement toxics 
use reduction (TUR). 3 

A second study 4 examined whether the facility planning required under the Massa¬ 
chusetts Toxics Use Reduction Act (TURA) provided a means to encourage com- 


2 Ross and Associates. Pollution Prevention Planning Effectiveness Study. Prepared for Washington 
Department of Ecology (1995). 

3 Massachusetts DEP. Massachusetts Toxics Use Reduction Program (Presentation; 1995). 







Chapter 7 - Measuring Pollution Prevention 


panies to integrate pollution prevention planning into their core business opera¬ 
tions and planning processes. The study examined the perspectives and actions of 
environmental managers at 10 of the 21 companies in the paint and coating indus¬ 
try subject to TURA. 

This study combined in-depth interviews with the companies’ environmental manag¬ 
ers with an evaluation of quantitative facility data (e.g., three-year history in genera¬ 
tion of toxic pollutants, hazardous waste, and volatile organic compounds emissions). 
In addition, each company’s past compliance history was reviewed to assess the poten¬ 
tial for pollution prevention and the accuracy of information obtained from the inter¬ 
views. 

The study concluded that almost all of the environmental managers at these com¬ 
panies regarded the TUR planning process as simply another compliance require¬ 
ment, although some felt that the process might nonetheless generate some useful 
information on environmental impacts, production processes, or environmental man¬ 
agement costs. 

Technical Assistance Evaluations 

North Carolina measures the results of on-site visits with follow-up surveys of the 
facilities visited. The state uses the survey findings to shape subsequent program 
modifications. Specifically, North Carolina’s Office of Waste Reduction sends out a 
survey form to facilities receiving on-site technical assistance. The specific pollution 
prevention actions recommended to the facility are listed, and the facility is asked 
whether it has implemented or plans to implement those measures. Where the mea¬ 
sures have not been implemented, customers are asked to specify one of the following 
reasons: not technically feasible, low return on investment, payback period too long, 
would slow production, or better solution found. 

The response rate to the survey from facilities served in FY 93-94 was 58 percent. 4 5 
Of those responding to the survey, 96 percent had implemented at least one of the 
measures recommended. Overall, 56 percent of the recommended measures were imple¬ 
mented. The survey does not try to distinguish whether the implemented measures 
were already under consideration by the facility prior to the on-site visit. Information 
from the surveys has been used to alter and better target subsequent reports and recom¬ 
mendations resulting from on-site visits. 

The Iowa Waste Reduction Center (IWRC), which works primarily with smaller busi¬ 
nesses, uses follow-up telephone calls six months after all on-site pollution preven¬ 
tion technical assistance visits to determine which recommended measures have been 
implemented, as well as the resulting reductions in waste generation. This informa- 


4 Greiner, Timothy J. The Environmental Manager’s Perspective on Toxics Use Reduction Planning, 
thesis for M.S. in Management and Master of City Planning degrees, Massachusetts Institute of 
Technology (June 1994). 

5 North Carolina Office of Waste Reduction Follow-up Survey. North Carolina Department of 
Environment, Health and Natural Resources; Division of Pollution Prevention and Environmental 
Assistance, FY 94-95 Annual Report, Appendix A. 


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Chapter 7 - Measuring Pollution Prevention 


tion is maintained in a database and is used to assess ways to modify the program. 
For example, the state recognized that implementation rates for pollution prevention 
changes involving higher capital outlays were low. Subsequently, a relationship was 
developed with the Iowa Small Business Development Centers to provide facilities 
with financial assistance. 

IWRC also did a mail survey of 200 businesses that it had previously served. 6 
The survey data were used to identify the types of recommended pollution pre¬ 
vention measures that small businesses have failed to implement and to deter¬ 
mine the barriers that impede the implementation of these measures in order to 
refine future program efforts. The findings included the following: 

■ Input material changes (primarily switching to non-hazardous solvent) were 
implemented by only 24 percent of respondents, primarily because they were 
not convinced that the non-hazardous alternative would work as well as the 
hazardous solvent, or they perceived that they had too little time (or generated 
too little waste) to make the changes. 

■ Technology changes were only implemented 38 percent of the time. The 
reasons for this were too little time, too little waste to bother with the change, 
the cost of the equipment, or quality concerns. 

■ Suggestions to use and reuse hazardous materials were implemented 57 percent of 
the time. When not implemented, it was due to the cost of implementation, 
lack of knowledge, or too little waste. 

The Massachusetts Office of Technical Assistance (OTA) utilized a telephone sur¬ 
vey as well as in-depth, on-site interviews to assess the effectiveness of pollution 
prevention technical assistance provided as part of a pollution prevention project 
in central Massachusetts during 1989-1992. 7 The project focused on metal-using 
industries in the Upper Blackstone River watershed. Technical assistance offered 
under the project consisted of workshops, telephone assistance, on-site assistance, 
and financial analyses. 

The survey consisted of telephone interviews of 110 companies. The sample was 
designed to provide a matched comparison of facilities inside and outside the project 
service area. In addition, 28 in-depth personal interviews were conducted at compa¬ 
nies to evaluate their post-project assessments of the OTA effort. The results of the 
survey indicated that OTA activities had an impact on implementation of toxics use 
reduction measures as follows: 

■ Of the firms receiving on-site assistance from OTA or attending OTA work¬ 
shops, 86 percent undertook toxics use reduction, as opposed to only 39 percent of 
similar firms in the same region. 


6 An Evaluation of Small Business Pollution Prevention Assistance. Small Business Pollution 
Prevention Center, University of Northern Iowa (June 1995). 

7 Central Massachusetts Pollution Prevention Project: Summary Report. Massachusetts Office of 
Technical Assistance (1994). 


224 







Chapter 7 - Measuring Pollution Prevention 


■ The percentage reduction of chemical use inside the Central Massachusetts 
area was higher than outside. 

■ Over half the companies that attended OTA workshops or had on-site OTA 
assistance said that OTA influenced them to make reductions. 

■ OTA’s clients were generally favorable about the usefulness of OTA assistance, 
with workshops and on-site assistance rated highest. Companies felt, how¬ 
ever, that OTA needed more industry-specific technical expertise, and should 
do a better job of marketing its services. 

■ The cooperation of regulatory and non-regulatory agencies increased utiliza¬ 
tion of OTA services, resulting to some extent in two-thirds of the 40 site-visit 
requests received by OTA. 

Community Efforts to Measure the Effectiveness of P2 Programs 

On a local scale, many communities are attempting to measure their progress in 
achieving pollution prevention goals. Most communities lack the resources to 
conduct large-scale assessments of pollution prevention programs like those de¬ 
scribed in the previous section. Communities can make these determinations by 
relying on indicators based on data gathered by local and state government agen¬ 
cies, academic institutions, and non-profit organizations. For example, data on 
waste generation and pollutant emissions could be used as indicators of pollution 
prevention progress. Hart Environmental Data compiled a database of indicators 
of sustainability that various communities have developed and used, alone or in 
combination, to measure their progress toward building sustainable communi¬ 
ties. 8 They include: 

■ Air pollutants from stationary sources (used for Minnesota Milestones); 

■ Commercial waste generation (used for Toronto Healthy City); 

■ Compliance with dissolved oxygen standards (used for Jacksonville Quality 
Indicator); 

■ Good air quality days (used for Greenville Community Indicator); 

■ Percent of waste stream recycled (used for Pasadena Quality of Life Index); 

■ Pesticide usage (used for Toronto Healthy City); 

■ Solid waste generated/recycled (used for Sustainable Seattle); and 

■ Toxic chemicals released or transferred (used for Minnesota Milestones). 


Hart Environmental Data at http://www.subjectmatters.com/indicators/ 


225 






Chapter 7 - Measuring Pollution Prevention 


Measuring Pollution Prevented 

A generalization can be made that there are only three outcomes for a toxic chemical 
once it enters a production process, and a case can be made that all three need to be 
tracked if pollution prevention is to be measured: 

■ The chemical can continue unchanged as an ingredient in a process or product. 

■ The chemical can be transformed into another chemical product (i.e., 
consumed). 

■ The chemical can wind up in the waste stream. 

Three methods commonly are used to quantitatively measure the amount of pollution 
prevented: actual quantity change, adjusted quantity change, and materials account¬ 
ing. Actual quantity change and adjusted quantity change focus only on chemicals 
that end up in the waste stream, whereas materials accounting takes product issues into 
consideration. The specific data requirements for these methods and their strengths 
and weaknesses as measurement tools are discussed further below. 

Actual Quantity Change (AQC) 

One of the simplest and most common ways companies and governments measure 
pollution prevention is by calculating the difference in the actual quantities of haz¬ 
ardous waste generation between two time periods. Quantities may be specified in 
terms of volume, weight, or other units of measurement. The actual quantity change is 
an absolute measurement, calculated by subtracting the quantity of waste generated in 
the previous period or a specified baseline period from the volume in the current pe¬ 
riod. 

AQC measurement is most often used when the goal is to get a sense of waste genera¬ 
tion trends. It is easy to implement, uses data that are readily available, and can 
measure changes in chemical use or waste generation at the process, facility, state, or 
national levels. 

Facilities subject to RCRA or TRI reporting requirements must keep track of hazard¬ 
ous waste generation or chemical releases before treatment, recycling, or disposal. 
These data can be used by the facility to calculate actual changes in hazardous waste 
generation and can be used to identify trends. Similarly, the data can be used at the 
state or federal level to measure actual quantities of toxic substances released into the 
environment and to identify broad trends in waste generation. 

Measurement of actual quantity changes may give some indication of whether pollu¬ 
tion is being prevented, but factors other than pollution prevention activities — such 
as a decrease in production or an increase in the amount of toxic chemical shipped in 
the product — could also result in a reduction in wastes generated. 


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Chapter 7 - Measuring Pollution Prevention 


Adjusted Quantity Change 

Measuring the adjusted quantity change separates the effects occurring as a result of 
changes in production from those occurring as a result of pollution prevention. Ad¬ 
justed quantity change measurements are actual quantity change measurements ad¬ 
justed or normalized by using a production or activity index. By adjusting for varia¬ 
tions in production, the adjusted quantity change more closely measures pollution pre¬ 
vention efficiency than the actual quantity change measure defined above. 

If a chemical is used at a facility for multiple purposes, different production indexes 
can be used for that chemical. TRI requires companies to file a production index for 
each toxic chemical the facility is required to report; however, the index is reported 
on a facility-wide basis. In cases where the chemical has multiple uses, it may not be 
meaningful to use a facility-wide production activity index. A study of New Jersey 
companies concluded that for more than 60 percent of the facilities, the facility-wide 
production index could not be used for pollution prevention index purposes. 9 

Facilities often have trouble constructing proper production indexes. The Washington 
State Department of Ecology has looked at plant level planning reports and TRI re¬ 
ports and has observed that the production indexes varied widely by facility and also 
within industry sectors. In some cases, the index used was not connected to the pri¬ 
mary process that used the hazardous substance or generated the wastes. In many 
cases, especially in high technology sectors, products changed from one week to the 
next, making the determination of a single meaningful and comparable production 
index very challenging. In such cases, adequate definition of indexes is essential for 
obtaining accurate pollution prevention measurement. 

Materials Accounting 

Materials accounting tracks specific chemicals as they move through the various steps 
and processes at a facility. Quantities of the chemicals are recorded at various loca¬ 
tions on their path. Total inputs of the chemicals should generally equal total outputs; 
however, there is no requirement or standard applied to the level of “closure” or 
“balance” to be achieved. Materials accounting is a less intensive approach than a 
traditional “mass balance” where the degree of closure is very precise. 

Data obtained through materials accounting (also referred to as throughput data) pro¬ 
vide important information for measuring pollution prevention. The technique quan¬ 
titatively tracks substances through a production process, and all materials entering 
the process must be accounted for upon leaving the process. No other environmental 
reporting system requires facilities to link material usage and products manufac¬ 
tured to waste generation and quantities released in the environment. 


9 Hearne, Shelley. Materials Accounting as a Potential Supplement to the Release Inventory For 
Pollution Prevention Measurement Purposes: A Case Study Analysis of New Jersey Throughput and 
TRI Data. 


227 



Chapter 7 - Measuring Pollution Prevention 


Materials Accounting in New Jersey 

New Jersey’s Department of Environmental Protection measured pollution pre¬ 
vention success using TRI data and facility-level materials accounting data, which 
New Jersey facilities are required by state law to submit. Measurements of waste 
generation based on the TRI data did not necessarily correspond to pollution pre¬ 
vention activities at the case study facilities. When materials accounting data 
were combined with the TRI data, a more comprehensive analysis of pollution 
prevention progress was obtained — reductions in quantities used were associ¬ 
ated with pollution prevention activities. 

Another important benefit of materials accounting is that it identifies how toxic 
chemicals end up, not just in wastes, but in manufactured products as well. For 
example, the INFORM Toxics Watch 95 review of New Jersey materials account¬ 
ing data found that of 124 million pounds of ozone depleting chemicals used as 
inputs statewide, only 3 percent (3.8 million pounds) ended up as waste. 10 In 
contrast, 58 percent (72 million pounds) of the input went to products containing 
the ozone depleters. This amount is much larger than the waste volume, which 
demonstrates the need to consider the entire product life cycle in order to get a 
comprehensive picture of the pathways of toxic pollutants. 


The first half of a materials ac¬ 
counting analysis quantifies in¬ 
puts to the facility and includes: 

(1) beginning chemical inven¬ 
tory; (2) quantity of chemical 
brought on-site; (3) quantity of 
chemical produced on-site; and 
(4) quantity of chemical re¬ 
cycled and reused. The second 
half of the materials accounting 
analysis quantifies outputs from 
the facility and includes: (1) 
quantity of chemical consumed; 

(2) quantity of chemical 
shipped as or in product; (3) 
quantity generated as non-prod¬ 
uct output; and (4) ending 
chemical inventory. 


Materials accounting uses infor¬ 
mation that is collected routinely at facilities for business or inventory management 
purposes. Among these data are: records of shipments of raw materials into a facility and 
records of the specific amounts of chemicals in products. Materials accounting also uses 
data required by other environmental regulations, including manifest data required under 


RCRA. 


Materials accounting can help identify pollution prevention opportunities within a fa¬ 
cility. Pollution prevention requires a focus on sources of waste generation prior to 
recycling and treatment. Materials accounting provides the framework for tracking 
raw materials to the locations and activities where they are lost from the process, the 
point where money is lost and environmental problems begin. Attaching the full 
internal environmental cost to specific activities, rather than spreading the cost over 
an entire plant, can help justify expenditures on pollution prevention technologies. 


In addition, materials accounting provides data for tracking trends in the levels of 
hazardous substances contained in products. Changes in plant operations that increase 
the level of hazardous substances into products can be identified. As mentioned 
previously, product data are necessary for measuring facility-level pollution prevention 
efforts. Products also can have environmental impacts once they leave the facility. 
In some cases, it may be waste streams at the consumer level that pose the greatest 
challenges for reducing the entry of toxic materials into the environment. The 
important role of products is reflected in the increasing use of life cycle assessment. 
These evaluations explicitly recognize that products must be followed beyond the 
plant gates in order to have a complete understanding of the potential for pollution. 10 


10 U.S. EPA. 1994. Issue Paper #2. Expansion of the Toxics Release Inventory (TRI) to Gather Chemical 
Use Information: TRI-Phase 3. U.S. Environmental Protection Agency, Office of Pollution Prevention and 
Toxics, Washington, D.C. 


228 











Chapter 7 - Measuring Pollution Prevention 


Other Measures for Pollution Prevention 

In addition to measuring the quantities of pollution prevented, efforts are being made 
to devise methods that will account for the varying degrees of hazard reduction when 
different wastes are reduced at facilities. Currently, there is no widely-accepted sys¬ 
tem for ranking the hazard potential of different chemicals, but work is in progress to 
create a measurement system that will take into account the fact that equal reductions 
in quantities of highly toxic substances and less toxic ones are not equivalent from a 
human health or environmental perspective. Recent efforts to develop a method that 
takes into account both toxicity change and quantity change are discussed below. 

Toxicity Change 

Toxicity change, a risk-based measure, attempts to assess pollution prevention progress 
based on changes in the toxicity or other hazard for pollutants generated or released. 
The difficulty lies in ranking the relative risks posed by individual chemicals. Does 
the risk to workers exposed to chemicals outweigh the potentially harmful effects 
chemicals have on the environment? Should chemicals resulting in acute health ef¬ 
fects receive priority over chemicals that may cause chronic health problems? 

Some states and research institutions have developed rankings of the Degree of Haz¬ 
ard (DOH) of waste streams. These DOH systems are designed to categorize waste 
streams based on the risk posed to human health and the environment. They do not, 
however, measure pollution prevention in terms of quantities of pollution prevented. 

Combining Quantity Measurements with Hazard Values 

Under a Pollution Prevention Incentives for States grant, the Indiana Pollution Pre¬ 
vention and Safe Materials Institute (IPPI) devised a pollution prevention measure¬ 
ment that incorporates hazard rankings for chemicals. This technique combines 
information on worker exposure and environmental hazard for each chemical to cre¬ 
ate a “hazard value” that is subsequently applied to the quantity of the chemical used 
or generated. First, a company must identify all hazardous chemicals used in a given 
process. For each chemical, the company then determines the amount used during 
specified periods, both before and after a pollution prevention strategy is implemented. 
These quantities are multiplied by the chemical’s “hazard value" to derive the “haz 
pounds” used of the chemical. The “haz pounds” for all chemicals used prior to 
pollution prevention implementation are then added together, and the result is di¬ 
vided by the units produced during this period. Likewise, all “haz pounds” of the 
chemicals used after pollution prevention implementation are totaled, and the result 
is divided by the units produced during the period. The two values are compared to 
determine whether the facility has achieved pollution prevention. IPPI is conduct¬ 
ing field trials using this method at wood products, plastic, metal coating/plat¬ 
ing, and automotive parts manufacturing facilities. In addition, research is being 
conducted to determine hazard values for more chemicals. 


229 




Chapter 7 - Measuring Pollution Prevention 


Environmental Accounting and Reporting System 

Polaroid Corporation uses a company-wide tracking system, the Environmental Ac¬ 
counting and Reporting System (EARS) to monitor progress of its Toxic Use and Waste 
Reduction Program. The EARS system tracks and quantifies materials at three critical 
source locations: (1) where materials are used; (2) where wastes are generated; and (3) 
when and how wastes leave the facility, including what happens to the wastes. 

All materials used and generated at the facility (approximately 1,700 chemicals) are 
grouped into five broad categories based on potential risk. The EARS system tracks 
and quantifies materials at different locations (e.g., input or output) for each risk 
category. The preferred reduction approach (e.g., use reduction, source reduction, 
recycling, etc.) also varies based on the risk level. For example, category I and II 
chemicals, which are human/animal carcinogens with known chronic toxicity, should 
be measured during input and controlled via use reduction. 

Future Directions and Conclusions 

The information presented in this chapter documents how pollution prevention has 
been measured by companies and local, state, and federal governments both in terms 
of pollution reductions and program effectiveness. The chapter provides a broad indi¬ 
cation of the measurement options available to companies and government agencies 
involved in pollution prevention. However, a number of questions still must be an¬ 
swered before we can fully determine how well we are doing nationally in preventing 
pollution. These questions include: 

■ Is measurement comprehensive? Is it able to capture outcomes when source 
reduction techniques are used? 

■ Does measurement account for production changes? 

■ Does measurement allow for tracking of facility performance over time? 

■ Does measurement allow for meaningful comparisons of two or more similar 
facilities? 

■ Does measurement support aggregation of performance of several facilities in a 
state or industry sector? 

The federal government is under increasing pressure to eliminate federal programs 
that are not successful, which has contributed to a growing urgency in the need for 
adequate measures of pollution prevention program effectiveness. In addition, the 
federal government is granting more regulatory flexibility to states. With this in¬ 
creased flexibility, however, comes greater responsibility on the part of states to dem¬ 
onstrate that they are still meeting environmental goals and objectives. To this end, 
many states are incorporating measures of program success into their project propos¬ 
als. For example, San Diego’s proposed Community XL Project would shift environ- 


230 





Chapter 7 - Measuring Pollution Prevention 


mental regulation of San Diego Bay businesses and industries away from traditional 
end-of-pipe strategies toward greater emphasis on pollution prevention. The pro¬ 
posal contains detailed plans for measuring program success using several types of 
evaluation measures. Quantitative measures will center on documenting cost savings 
and waste reductions. A pollution prevention index will compare key environmental 
and economic indicators. The index is a ratio of the quantity of pollutant discharged to 
the level of economic activity. 

The implementation of GPRA and NEPPS will contribute to a fundamental shift in 
how pollution programs are evaluated in the future. For example, the majority of 
state pollution prevention programs currently account for resources expended simply 
by tracking the level of activity of the program. With GPRA, however, the emphasis is 
on program performance (e.g., environmental benefits). Under NEPPS, the states and 
EPA also are focusing on programs outcomes as much as possible. This increased 
emphasis on actual performance of pollution prevention programs should lead to the 
development of more effective pollution prevention measures in the years to come. 


231 



Chapter 7 - Measuring Pollution Prevention 



Measuring Pollution Prevention Progress 

by 

Ken Geiser 

Toxics Use Reduction Institute 
University of Massachusetts Lowell 



and 


Elizabeth Harriman 

Toxics Use Reduction Institute 
University of Massachusetts Lowell 


“I often say that when you can measure what you are speaking about, and express it in num¬ 
bers, you know something about it; but when you cannot measure it, when you cannot express 
it in numbers, your knowledge is of a meager and unsatisfactory kind, it may be the beginning 
of knowledge, but you have scarcely in your thoughts, advanced to the stage of Science what¬ 
ever the matter may be. ” - Lord Kelvin 

We measure things to understand them, to account for them, and to manage them and improve their performance. 
When we operate industrial production facilities, we take things from the environment; convert, manufacture, and 
assemble these things; and send them out as products and services that make our lives better. We also send out the 
wastes, effluents, and emissions that are the residual byproducts of production. In order to justify the benefit of 
industry we must ensure that the risks to the environment and our health do not outweigh the benefits of products 
and services. 

Measurement is the bedrock of science. We can not understand the relationship between industrial activity and 
environmental quality if we do not measure industrial impacts and do not seek out and study possible effects. 
Plotting trends in indicators of terrestrial, marine or atmospheric chemistry and biology provides a means of 
understanding the consequences of anthropocentric activities. Similarly, tracking indicators of industrial activ¬ 
ity provides knowledge of the sources of contaminants. Studying the effects of heavy metals in aquatic environ¬ 
ments or the interactions of volatile compounds in the atmosphere increases our knowledge, but it is only when 
we can correlate those effects with their releases from generators that we understand how we affect the environment. 

Preventing pollution is a complex process requiring an understanding of production systems, industrial tech¬ 
nologies, control apparatus, operational efficiencies, market conditions, regulatory requirements, and the fate of 
substances in the various sectors of the environment. Defining adequate indicators of pollution and meaningful 
indices of prevention is not trivial. Measuring something that exists, such as pollution, is always easier than mea- 


232 











Chapter 7 - Measuring Pollution Prevention 


suring that which has been prevented. In addition, the wide variations in generators, the differences among pollut¬ 
ants, the diverse methods of collecting data, and the differing baselines from which companies begin measuring 
mean that there will be no simplistic or singular way to measure pollution prevention. Yet, pollution prevention 
does require some common coherence that is only recently emerging. This will require a documented body of 
experience and practice, a consensus on terms and definitions, a set of replicable data collection methodologies, 
and stable and understandable methods of analysis. 

Measurement provides the foundation for accountability. The policy transition from pollution control to pollution 
prevention reconfigures the conventional relationship between industry and government from an adversarial, com¬ 
pliance-oriented system to a more cooperative system of shared responsibilities. Improving the environmental 
performance of firms has become an environmental program in the same way that improving childhood reading 
scores is an educational program. Like government-sponsored reading advancement programs, government-spon¬ 
sored pollution prevention programs require public accountability and accountability requires the periodic assess¬ 
ment of progress. Public investment in pollution prevention engenders a responsibility to measure and assess 
progress. 

Recent state and national experiments with alternative means of assuring environmental performance from in¬ 
dustrial facilities rely less on permit writing and compliance. These programs must still guarantee a credible means 
of accountability. Self-reporting and third party audits require some commonly accepted metrics. While the per¬ 
formance indices in early demonstrations may vary significantly, as programs stabilize and mature they will require 
measurement systems that are consistent, focused and self-validating. Environmental protection programs that are 
flexible and well tailored to facility capacities will still need measurement systems that assure the public that 
pollution is reduced and environment quality is improved. 

Finally, measurement is the key to managing and improving what we make. There is an old quote: “If you can’t 
measure it; you can’t manage it.” Preventing pollution, like optimizing production, is fundamentally a manage¬ 
ment problem. There will be new technologies and new materials that offer opportunities for more environmen- 
tally-conscious manufacturing, but selecting these and employing them to their greatest advantage will be deter¬ 
mined by management. Leading firms today identify opportunities to reduce pollution, calculate savings, con¬ 
vert systems and evaluate effectiveness by maintaining and analyzing data collection systems. Like quality 
assurance systems and loss control procedures these pollution prevention systems require setting goals and measur¬ 
ing progress. 

A good facility pollution prevention system should build recognition, validation and learning into the daily 
practice of data collection. Nor should measuring pollution prevention be an isolated endeavor. Data collection 
that is not integrated into the techniques of production management and business accounting will always appear 
as a conceptual and financial burden. Like the speedometer on a car, an effective measurement system needs to 
collect data naturally from the functioning of the process, report it in a timely manner, and provide a feedback 
loop that encourages analysis and correction. 

The responsibility to measure and assess pollution prevention programs is driven by several commitments—the 
need to promote progress, the need to validate performance, the need to appropriately target public investment, 
the need to inform the public—but, primarily, it ensures that the public trust upon which environmental protec¬ 
tion must be based, can be, achieved without the imposition of government authority. To promote pollution 
prevention without metrics and without goals for measurement would promote activity instead of movement and 
reward effort instead of achievement. Constructing valid and appropriate systems for measuring pollution preven¬ 
tion progress is critical to the further development of this young field. 


233 



Chapter 7 - Measuring Pollution Prevention 


234 











Chapter Eight 

Tlie Future of Pollution 
Prevention 


■ Guest Comments: 

Joseph T. Ling, 3M 

Warren R. Muir, Hampshire Research 
Associates, Inc. 

David L. Thomas, Illinois Department of 
Natural Resources 

Harry Freeman, University of New Orleans 
Joanna D. Underwood, INFORM, Inc. 
Gerald Kotas, U.S. Department of Energy 

.* v f\\\\\YZt 




Chapter 8 - The Future of Pollution Prevention 


236 





Chapter 8 - The Future of Pollution Prevention 


Introduction 

What does the future hold for pollution prevention? To address this question, we 
enlisted the help of a number of guest authors, including some former EPA employ¬ 
ees. This was not an attempt to provide a “balanced” set of viewpoints on prevention 
pro and con. Rather, we identified these authors because of their exceptional 
contributions and long-standing commitment to prevention. 

Not surprisingly, no consensus emerges on the future of pollution prevention from 
our guest commenters. Some are sanguine, others less so. Harry Freeman believes 
that the future holds environmental successes not even dreamed of today. Warren 
Muir is pessimistic that despite a great deal of activity related to pollution prevention, 
it has had no discernible impact on aggregate toxic chemical waste generation and 
industrial practices in the United States. Joanna Underwood wonders if we have been 
measuring the wrong thing — there are 4 billion pounds of toxic releases, but 6 trillion 
pounds of chemicals in commerce. 

Concerns such as these lead to additional questions about how pollution prevention 
can be incorporated into the way Americans live and work: 

■ How do we put prevention in the larger context of other paradigms for 
environmental protection? 

■ How do we take advantage of opportunities to prevent pollution and minimize 
waste in consumer products? 

■ How do we make prevention a meaningful concept for business and govern¬ 
ment decisionmakers? 

■ How do we build new partnerships and constituencies for pollution preven¬ 
tion? 

Our guest authors have valuable perspectives on some of the key challenges that we 
face in answering these questions: 

■ Prevention and sustainability : Joseph Ling, Joanna Underwood, Gerald Kotas, 
and David Thomas all look at prevention in the context of progress towards 
sustainable development. For our contributors, pollution prevention is not an 
end in itself, but a means for reaching the larger goal of sustainability. 

■ Prevention and products : Joseph Ling, Harry Freeman, and Joanna 
Underwood see consumer products as the next challenge for prevention, 
recognizing that public health risks and the limitations on the benefits we 
can get from working with industrial processes. Of course, the question of 
what makes one product “greener” than the next is a source of much debate. 
This report touched on the issue of moving the market towards environmen- 
tally-preferable products in Chapter 2. 


237 


Chapter 8 - The Future of Pollution Prevention 


■ Reaching to right decisionmakers : Warren Muir and David Thomas point to the 
need to reach the people within companies who make the decisions, those 
responsible for product and process design and operations. 


■ Tapping new partners and participants'. All of our guest commenters suggest 
that the challenge of the future requires a broadening of participation in 
pollution prevention — from tapping the enthusiasm of our youth, according to 

David Thomas, to Gerald 

Have We Piqued Your Interest? 


Readers interested in the burgeoning literature on the future of pollution preven¬ 
tion can also look at: 


Kotas’ call for new partner¬ 
ships that lead to creative 
solutions and fundamental 
lifestyle changes. 


■ “Why the Pollution Prevention Revolution Failed — and Why It Ultimately 
Will Succeed” by Joel S. Hirschhom. Pollution Prevention Review. 

(Winter 1997). 

■ “The Unfinished Business of Pollution Prevention” by Kenneth Geiser. 
Georgia Law Review Volume 29:473 (1995). 


How far have we come and 
how far do we have to go? 
Listen to what our contribu¬ 
tors have to say and decide 
for yourself. 


■ Frontiers in Pollution Prevention from The Michigan Great Lakes Protec¬ 
tion Fund. Available through the Tellus Institute (617-266-5400). (August 
1996). 


238 


Chapter 8 - The Future of Pollution Prevention 


Next Stop: Designing for Sustainability 

by 

Joseph T. Ling 

Vice President, Retired 

Environmental Engineering and Pollution Control 
3M 

St. Paul, Minnesota 

Pollution prevention has come a long way in the last several decades. It has been incorporated in public policies 
and private practices worldwide. The adoption of the Pollution Prevention Act in 1990 further strengthened the 
application of pollution prevention in this country. Pollution prevention has proven itself a powerful and effi¬ 
cient tool in making manufacturing facilities more environmentally friendly. 

But a new horizon is appearing in environmental issues — that of sustainable development. We now need to apply 
the lessons learned from pollution prevention to this new approach, which should be both a goal and an agenda for 
nations to pursue in the coming century. Sustainable development involves many factors, including economics, 
renewable and nonrenewable resources, and social, health, and ecological concerns. Because sustainable develop¬ 
ment grew out of a concern for the environment, I believe that the principles used in environmental protection will 
also help to achieve this new goal. The concept of prevention is the basic building block for achieving sustainable 
development. 

Looking back at where we’ve been: In the 1960s, we emphasized pollution control. We added equipment that 
removed pollutants before they reached the natural environment. Unfortunately, you cannot make pollutants 
disappear. In almost all cases, you only change them from one form to another, which can lead to cross-media 
transfer of pollutants. 

In the 1970s, industry moved another step forward by searching for alternative solutions to the pollution prob¬ 
lem. At 3M, we began looking into the manufacturing process for ways to eliminate pollution at the source, before 
cleanup problems occurred. Pollution prevention was a logical extension of pollution control. However, neither 
can assure sustainable development and growth. That’s because control and prevention efforts address only what 
occurs inside the plant; they do not consider downstream problems. 

The next logical step for industry was to deal with the environmental impact of products after they leave the 
factory, which has been referred to as Design for the Environment. My definition of designing for the environment 
is a “design process involving all environmental constraints and opportunities and producing no or minimum 
damage to the environment from the raw material selection, production, and product use, to its final disposal, as 
the design objective.” At 3M, for example, we designed a solvent-free adhesive for our popular Scotch brand 
Magic Transparent Tape to avoid air pollution. 

Another example of designing for the environment is the elimination of chlorofluorocarbons (CFCs) from auto 
air conditioners. At chemical plants, CFCs are no longer being manufactured for use in the coolant, eliminating 
an on-site pollution problem. Further, auto companies don’t use CFCs to charge air conditioners. And you and 
I don’t contribute to the problem when we go to repair garages to have our car air conditioners recharged because 
they use a CFC-free refrigerant. CFC pollution was designed out of the manufacturing process from the beginning 
of the process to the end. 



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And yet, even diligent application of Design for the Environment cannot achieve sustainable development and 
growth because the environment is only one of the many elements involved in sustainability. The next logical 
step is what I call Design for Sustainability. The sustainability of a desired quality of life for all people, for 
future generations, will depend upon the establishment of sustainable systems in multiple spheres: 

■ A sustainable economic system needs to provide for the essential needs of people and generate additional 
wealth. 

■ A sustainable social system needs to provide for the general well-being of the population, including 
resolving tensions that occur when conflicts arise about which actions to take. 

■ A sustainable value system needs to be conservation-oriented with regard to all renewable and non¬ 
renewable resources. 

■ A sustainable technical program must be oriented to continue providing new solutions to existing and 
emerging problems. 

In this context, we should think of Design for Sustainability as a “decision-making process that aims at achieving 
maximum benefits with minimum use of resources, by integrating all economic, social, human, environmen¬ 
tal, and ecological concerns.” 

For industry, Design for Sustainability fills the gap between Design for the Environment and Sustainable 
Development and Growth. It is similar to a natural ecological system in which waste produced by one part of 
the system becomes a raw material for other segments of the system. For example, one 3M plant generates 
waste plastic from the manufacture of computer data cartridges. Another 3M plant uses this waste plastic to 
manufacture antistatic trays for handling computer chips. The ideal Design for Sustainability is a closed- 
loop, zero-discharge system in which every waste is recycled completely, providing others with a source of 
raw materials or energy. 

To contrast where we’ve been with where we are headed, consider the model for the conventional pollution 
control and pollution prevention approach to environmental management of the 1960s. It consists of three 
elements: 

■ Raw materials enter from the left. 

■ Products emerge from the right. 

■ Waste is created and recycled back into the system or treated. 

The model for a Sustainable Growth is better thought of as consisting of three circles within each other: 

■ In the center, raw materials and waste are together, representing the alpha and omega of production. In 
this area, environmental management focuses on pollution control and pollution prevention. 

■ The next circle includes raw materials, product design, energy conservation, and product use and dis¬ 
posal. This circle represents Design for the Environment, an extension of the pollution prevention concept. 

■ The outside ring includes not only everything in the inner circles, but also ecological concerns, health and 
safety concerns, and availability of natural resources. This is where we establish Design for Sustainability. 


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All segments of society have a role in sustainable development: 

■ Government should build the principle of Design for Sustainability into decisions to amend or create 
policies and regulations, not only for environmental enhancement, but also for economic development, 
transportation, land use, and energy development. 

■ Academia needs to provide education, training, and new scientific and technical knowledge. 

■ The public must demand, and be willing to support, appropriate government and private-sector actions. 
Also, the public must be open to the idea of modifying patterns of consumption and lifestyle that are in 
conflict with the principles of sustainable development and sustainable growth. 

■ Industry must develop and implement manufacturing processes, new products, and services that are 
congruent with the principle of Design for Sustainability. 

Together, government and industry must support and fund research in academic institutions to develop appropri¬ 
ate technologies and accelerate transfer of this technology to industrial and other applications. 

Although we have gained a lot of knowledge and experience in four decades with environmental protection as a 
top public concern in this country, we still find ourselves without complete information and, again, have to act on 
the basis of incomplete information. However, let’s remember that a trip of a thousand miles begins with a single 
step. We need to take that step and not worry about stumbling tomorrow. What we do today can make a 
difference tomorrow, and for generations to come. 


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Facing Facts 

by 

Warren R. Muir, Ph.D. 

President 

Hampshire Research Associates, Inc. 
Alexandria, Virginia 


Over the past two decades the field of pollution prevention has been characterized by what is possible — by win- 
win options to dramatically reduce the environmental impacts of industrial operations while actually making com¬ 
panies money. Cliches about “waste reduction” in the 1970s yielded to debates in the 1980s over the definition of 
“pollution prevention,” with a clear resolution in the 1990s that the field is centered in changes to process inputs and 
operations and to products, rather than to waste management. 

The 1991 Pollution Prevention National Report documented the emergence of a new field. State pollution preven¬ 
tion programs were blossoming across the country. In 1990, Congress had just enacted the Federal Pollution 
Prevention Act, making source reduction the top of a hierarchy of environmental management options. EPA lead¬ 
ership endorsed pollution prevention as its highest priority approach to its mission and established a pollution 
prevention office to oversee its adoption throughout Agency programs. Numerous pollution prevention initiatives 
were launched by industry, some within companies, others across whole sectors of the economy. 

It has been hard not to be optimistic about the future of pollution prevention with the concept of pollution preven¬ 
tion being nearly universally endorsed as the best environmental management strategy by industry, government, and 
the public interest community; with pollution prevention being economically in the interest of companies as well as 
the economy as a whole; with an apparent plethora of pollution prevention initiatives that could be implemented 
quickly; and with an ever increasing number of individuals and firms experienced in pollution prevention. 

But let’s face the facts. Pollution prevention to date has had no discernible impact on aggregate toxic chemical 
waste generation, and industrial practices in the United States. Waste generation reported to the Toxics Release 
Inventory is slowly rising and projected to continue to do so. The number of source reduction activities reported 
has declined each year. In industry, institutional barriers within companies continue to limit adoption of this ap¬ 
proach. Too often the only people within companies with any pollution prevention responsibilities are those from 
Environmental Affairs and they are seldom the ones responsible for process design and operations within compa¬ 
nies — the only folks who can carry out pollution prevention. 

Moreover, pollution prevention is not at the center of environmental public policy today. The many ongoing discus¬ 
sions of, and experiments with, regulatory reform seem much more focused on the assessment of risks from indus¬ 
trial operations than on the cost saving options of pollution prevention. In addition, pollution prevention planning, 
once proposed as a national strategy and endorsed by industrial groups, is now under attack by some of the same 
groups in the few states which have attempted the approach. 

Those of us in the pollution prevention community need to wake up and consider some new approaches to improve 
the future for pollution prevention. There is no reason to believe that there are any fewer pollution prevention 
opportunities now than there were two decades ago, when the field was just emerging — but we have yet to learn 
how to tap the environmental and economic benefits of such opportunities. We’ve learned how to talk pollution 
prevention, but are a long way away from putting it into action nationally. 


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| Sustaining Pollution Prevention 

David L. Thomas 

Director 

Wmt ^ Waste Management and Research Center 

■ Wmm Illinois Department of Natural Resources 

Champaign, Illinois 


We are in the midst of an environmental revolution, one that we will all be a part of and that will affect all of us. 
The success of this revolution will shape what our world will look like in the future, and its impact will be felt on 
the corporate world, on individuals, and on our institutions. We are presently in a stage of experimentation, the 
trying of new ideas and projects in search of a better, more long lasting answer to our environmental, social, and 
economic problems. It will fall on all of us to analyze the impact of these experiments and to set a policy course 
that can lead us to a more sustainable future. 

Some common themes are emerging from a number of different disciplines and viewpoints. Whether we are 
concerned with protection of natural areas, maintaining biodiversity, pollution prevention, design for the envi¬ 
ronment, industrial ecology, or sustainable development, the common theme in all of these concepts is an emphasis 
on the environment as an important component in our planning and thinking. Whether we are a member of a local 
planning board, a design engineer for a major company, a politician or policy maker, a factory worker, or teacher 
— we all have an important role to play in the environmental protection strategy of the future. 

Pollution prevention in its simplest form is the reduction of the amount and/or toxicity of waste before it is ever 
generated. It is a concept that has quickly taken us beyond our traditional “command and control” approach to 
controlling waste and toxic emissions. Because the concept focuses on not generating waste in the first place, it 
has forced companies to look at the flow of chemicals in the workplace and to look at where and why wastes are 
generated. Environmental decision making has moved from the environmental manager back into the plant to 
the design engineers, process engineers, marketing personnel, accountants, and line personnel to name a few. 
Decisions related to pollution prevention have to be made before waste is ever generated, from those involved in 
product and process design and operation, to those making decisions about materials use. Involving people who 
have not traditionally had a role to play in environmental issues is a major challenge to a successful pollution 
prevention program. 

Another challenge to an effective pollution prevention program is properly accounting for the true cost of waste. 
Unfortunately, our environmental regulations have not asked companies to collect the specific data on the ori¬ 
gins of waste within an industrial facility that are needed to determine the appropriate pollution prevention strat¬ 
egy. It is only by understanding where and why waste is being generated that we can develop effective pollution 
prevention strategies. And it is only by having a good understanding of the cost of waste, particularly the cost of 
lost raw materials, that will lead a company to adopt many pollution prevention strategies that on the surface may 
look too expensive. 

Many progressive companies are looking beyond traditional pollution prevention strategies to make their com¬ 
panies leaders in an ever more competitive global marketplace. A number of companies have adopted "design 
for the environment” concepts, basically looking at the raw materials in one generation of product becoming the 
raw materials of the second generation of product. This concept requires that a large amount of forethought be 


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given to the products and processes to ultimately conserve valuable materials and resources. AT&T for example, 
requires environmental considerations to be incorporated into product design from the outset. AT&T’s vision is to 
be recognized by customers, employees, shareholders, and communities worldwide as a responsible company that 
fully integrates life-cycle environmental consequences into each of its business decisions and activities. Designing 
for the environment is a key in distinguishing their processes, products, and services. 

Some are now viewing industrial ecology as a more overriding concept that includes pollution prevention, 
design for the environment, and life-cycle analysis as tools to move us toward a more sustainable future. Graedel 
and Allenby in their book Industrial Ecology define it as: 

“the means by which humanity can deliberately and rationally approach and maintain a 
desirable carrying capacity, given continued economic, cultural, and technological evolution. 

It is a systems’ view in which one seeks to optimize the total materials cycle from virgin 
material, to finished material, to component, to product, to obsolete product, to ultimate dis¬ 
posal.” 

Industrial ecology, as applied to manufacturing, requires familiarity with industrial activities, environmental 
processes, and societal interactions, a combination of specialties that is rare . 

So, what does this portend for the future? It will require some major shifts in our thinking and in our basic 
environmental protection strategies. At least four things need to happen to make these changes successful: 

1) . Industry needs to take a leadership role in our future environmental protection strategies. According to 

Graedel and Allenby, responsible corporations may turn out to be among the global leaders in the transition 
between non-sustainable and sustainable development. I agree with this point, and have come to the 
conclusion that in the future, industry will need to take a leadership role in environmental protection, better 
uses of resources, and sustainable development. 

2) . Everyone has a role to play in sustainable development and environmental protection. There is a real need 

to change the way we educate our youth. If we are now saying to companies that for their pollution 
prevention program they need to involve design engineers, managers, lawyers, accountants, process 
engineers, etc., then colleges need to be training these people in the potential environmental role they will 
play when they enter the work force. We need to integrate environmental thinking and issues into a variety 
of curricula. 

3) . New partnerships will have to be formed for future environmental programs. Environmental protection 

will have to go well beyond the role of a state or federal regulatory agency just as it must go beyond the 
role of the environmental manager at a facility. Who will have an important role to play in the future to 
promote pollution prevention in businesses and industries? It may well be the bankers and accountants, 
the insurance providers, and the suppliers and vendors of chemicals and equipment. These are the 
trusted sources of information for small businesses, and they need to be giving an environmental message 
along with the other information they convey. The National Academy of Public Administration’s 1995 
report, Setting Priorities, Getting Results: A New Direction for the Environmental Protection Agency, 
stated that “to continue to make environmental progress, the nation will have to develop a more rational, 
less costly strategy for protecting the environment, one that achieves its goals more efficiently, using more 
creativity and less bureaucracy.” They see the goal of these changes as being a transition to a nation in 
which many more actors make better informed decisions and more efficient choices. 


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4). We need to consider the environmental consequences of all of our actions and we need to better determine 
the long-term costs and benefits of these actions. This is pertinent not only for an industry making deci¬ 
sions about the products it will make and the production processes it will need to make those products, but 
it is also important in considering our natural resources. Hundreds of millions of dollars are spent each 
year by people wishing to enjoy our natural resources, and yet we often fail to account for the economic 
value of our environment when we make decisions about land use and development. In the future, these 
natural resources will take on even greater value to those who wish to enjoy the environment around 
them. 

We are at a point in history where we are seeing major changes in the way governments operate. Environmental 
programs are in a state of transition. Vice President Gore stated that “we are at a crossroads. The decisions we 
make today will determine whether we leave to future generations an attractive, livable world or an ever-escalating 
series of problems. More than ever, we must work vigorously to advance the twin goals of environmental protec¬ 
tion and economic growth.” John Sawhill, president and CEO of the Nature Conservancy, stated in an inter¬ 
view with the Harvard Business Review “that integrating economic growth with environmental protection” is 
the conservation issue of the 1990s (Howard and Magretta, 1995). Pollution prevention has been an excellent 
approach to integrating economics and environmental protection. Now we must expand our thinking to look at 
pollution prevention as one of many tools needed to lead us to a sustainable future. 


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Chapter 8 - Guest Commentary 


Changing the Focus of Pollution Prevention 

by 

Harry Freeman 

Executive Director, 

Louisiana Environmental Leadership Pollution Prevention Program 
University of New Orleans 
New Orleans, Louisiana 


I remember when the term pollution prevention first appeared on the scene. That term, or P2, the increasingly 
popular short-hand version, has come a long way since it was coined in the mid 1980s. Then, it was a bold new, 
largely untried idea to refocus the nation’s regulatory attention further “up the pipe” and away from “end of the 
pipe” treatment options. Those who were around then must remember the seemingly endless discussions over 
just what the term did, and did not, mean. (And then there were those other ad infinitum discussions over the 
terms “waste minimization” versus “waste reduction.”) Today, while there is still a significant amount of disagree¬ 
ment over just what should be included under the P2 umbrella (even though EPA has really tried to sell its some¬ 
what restrictive definition), there is an extremely wide acceptance in both the public and private sectors that 
policies that encourage the elimination rather than just the control and treatment of pollution are good, and in the 
best interests of all concerned. However, there are still interminable discussions, but now they are about, “How do 
you measure P2?” 

So what of the future of P2? To slightly modify a well-known statement from the world of political campaigns, 
“It’s the products, stupid”. To date, probably because the movement came out of the EPA, most of the focus has 
been on hazardous industrial waste and toxics. Consequently, there have been truly impressive reductions in 
these areas and for this both the regulators and the regulated community are to be commended. However, to 
employ a probably overused P2 standard analogy, we may have just about picked all of the low hanging fruit on 
the hazardous waste and toxic waste branches. We need to look to the products themselves for a couple of 
reasons. Clean products will drive cleaner technologies and, consequently, will contribute to reducing environ¬ 
mental risks across the board. Clean products will represent much less of a threat to environmental quality when 
they are used, recycled, and disposed of. This is bad and good news for the EPA. The bad news is that the EPA 
with its traditional regulatory focus on reducing and/or treating waste streams may not be able to do much to 
encourage the development and production of clean products. The good news is that regardless of its involve¬ 
ment in the process, the Agency will be able to take credit for the enhanced environmental quality that will result 
from the changes. With this in mind, the Agency should continue to search for “new and improved” approaches 
for influencing clean product development. 

However, the truth may be that given the peculiar nature of cleaning up the environment by addressing products 
rather than waste streams, the EPA and its fellow State counterparts may not be the leaders. The leaders may 
turn out to be those agencies with more of an end product focus such as USDA for non-point source runoff and 
DOT for mobile sources of air pollution. Pollution prevention is a process rather than an end. This is often 
forgotten by the advocates who at times are so busy circling the wagons to protect the P2 programs from dilution 
into the greater scheme of things that they forget that it is only when the pollution prevention becomes second 
nature to all that we will reap the environmental benefits offered by the concept. 



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P2 advocates in the future are faced with the challenge of maintaining a high profile for the movement while so 
successfully incorporating pollution prevention into society’s various sectors that a high profile is no longer 
needed. 

I think the future is bright. There will certainly be disagreements among us as to just exactly how to pursue the 
goal, but I do not think there will be much disagreement about the goal itself. In fact, I think that as cleaner 
technologies continue to be adopted in all industrial sectors we will come to enjoy environmental successes not 
even dreamed of today. P2ers of the World Unite. We have only our inefficient and dirty production processes to 
lose. Onward! 


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Chapter 8 - Guest Commentary 


Moving Towards tHe Safe Use of Chemicals 
by 

Joanna D. Underwood 

President 
INFORM, Inc. 

New York, New York 


Over the last decade, the concept of pollution prevention has not only entered the stage of environmental think¬ 
ing but in a quietly revolutionary fashion made its way to front and center position. There is virtually no corner 
in either the public or private sector where it is not hailed as the number one strategy for addressing the potential 
hazards associated with the use of toxic substances and with industrial wastes. Its appeal has been not only its 
ability to affect dramatic reductions in plant wastes but also its potential for saving companies money, protecting 
workers better, and improving the efficiency of raw material use. 

The public spotlight on pollution prevention will grow brighter in the period ahead for a variety of reasons: 

■ Industry progress in reducing plant wastes at their source has been only marginal. While the chemical 
industry’s leadership has embraced the concept of pollution prevention and some companies have 
launched major plant-level initiatives, the message has clearly not yet penetrated in many plant opera¬ 
tions. National Toxics Release Inventory production-related waste generation data has essentially 
remained unchanged. This is not surprising when INFORM research, published in our Toxics Watch 95 
report, showed companies having sought pollution prevention options for only one quarter of TRI waste 
streams they reported to EPA. 

■ Public concerns regarding the safety of toxic chemicals are growing. The fact that barely 10% of all toxic 
chemicals in commerce have been well characterized for their impacts on public health or the environ¬ 
ment has long worried the U.S. citizenry. New information regarding the profound impacts that endo¬ 
crine disrupting chemicals may be having on animal species and perhaps directly on human reproduction 
has heightened concern. It comes as perhaps only the latest of a series of nasty surprises - which have 
included DDT, PCBs, CFCs, carcinogens, etc. Preliminary evidence suggests that this surprise may come 
closest to home - potentially affecting every family’s future. 

■ In the last decade we have realized that the threats to public and environmental health posed by toxic 
chemicals are much broader than we thought. While most public attention has focused on the some 4 
billion pounds of waste from U.S. chemical plants, this is only one of many sources. 

Toxics Watch 1995 produced two significant perspectives on where our toxics problems lie. In doing the first 
public analysis of the U.S. Chemical Production Index, we discovered that the 4 billion or so pounds of toxic 
industrial wastes is dwarfed in comparison the the more than 6 trillion pounds of chemicals flowing annually 
into commerce. Contamination may be caused by exposures (depending on how chemicals are used and handled) 
at many points in this commercial flow. 

Further, Toxics Watch 1995’s analysis of data on a variety of “contaminated environments” found contamination 
sources to be, to a significant degree, toxic constituents incorporated in products used throughout the society - 
from industrial solvents, to paints, to oven cleaners, to refrigerants, to adhesives, to pesticides. 



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Chapter 8 - Guest Commentary 


The President’s Council on Sustainable Development report this year has reinforced the importance of a new and 
more committed attack on this and other U.S. environmental problems. The PCSD report, representing a concensus 
of business, government and environmental leaders, has called for progress in this country toward truly “sustain¬ 
able” ways of living — one goal being to become a no-waste society. Yet from chemical making and using plants 
burgeoning in many parts of the world, the total global output of toxic wastes that must be managed and the 
overall flow of toxic chemicals through commerce is growing. 

The good news of the past decade has been emergence of a preventive way of thinking about safeguarding our 
environment and better understanding of the scope of the problems we face. Such growing awareness makes it 
possible for government to set more appropriate policies and for business leaders to anticipate the scale of 
change and innovation that will be needed in the short and long terms. 

What steps do today’s realities suggest? 

First, that the same kind of business innovation that gave us the world of chemical products that have enriched 
our lives be applied toward new ends. Ingenuity must be used to achieve much greater progress in plant-level 
pollution prevention but also to prevent exposures to toxic chemicals in product or anywhere else in their flow 
through commerce. The goal? continuous progress toward zero exposures. 

Second, to reassure the public that progress is occurring, data must be available that will enable citizens as well 
as government, as the chemical industry has said, to “track us” not “trust us.” Trust will certainly rely on such 
information showing a new level of progress. To provide an adequate overview, public information would have 
to include full materials accounting data, now proposed by EPA as an expansion of TRI, and ultimately better data 
on chemical uses, especially in products. 

If expanded information, combined with today’s voluntary incentive and technical assistance programs do not 
stimulate much accelerated plant pollution prevention progress, then government may need to take further 
action: to require the kind of pollution prevention planning such as mandated in New Jersey, and that companies 
have acknowledged has enhanced their achievements; or to consider stronger economic drivers such as waste fees. 

Third, the basic assumption underlying toxic chemical regulation - that chemicals are “innocent until proven 
guilty” - must be re-thought. The scant understanding that science has of chemical risks and the record of 
problems that have surfaced to date make this crucial. For newly proposed chemicals, the burden of proof has 
been on EPA to show risk before restricting production. Under this program only 4% of proposed chemicals 
have been restricted. More than 1000 new chemicals have entered commerce each year. Taking a preventive 
approach, it makes sense to place the burden of proof on manufacturers to show that new proposed chemicals 
ARE safe for intended uses - with approval then granted just for these uses. 

For the more than 70,000 chemicals already in commerce, EPA’s economic as well as “risk-based” burden of 
proof for regulation has been virtually impossible to meet. While broader testing is needed, even if sufficient 
proof of a chemical’s inherent toxicity were available, public policy’s reliance on inherent risk as the sole or even 
primary basis for regulation would need modification. An approach based on current knowledge must reflect the 
fact that threats posed by toxic chemicals are not just due to their inherent risk but to what they are used for and 
where and how they are used. Exposure prevention as toxic chemicals move through commerce, like pollution 
prevention at industrial plants, makes sense as a guiding principle. 


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Finally, it would help insure the greatest learning curve on chemical safety, which is certainly in our interest and 
that of our children, if the results of all chemical testing done in the public or private sectors were made public 
and if the use of confidential business information were minimized. 

While a number of leading chemical companies in the United States have recognized that successful continua¬ 
tion of their business relies on application of the pollution prevention concept and the concept of product steward¬ 
ship in whole new ways, many more companies, large and small, must follow. Those who understand that these 
concepts must now be defined within a national goal of becoming a “sustainable society” and that this is a real and 
vital new vision are those that will thrive in the global marketplace of the coming century. 


Chapter 8 - Guest Commentary 


Pollution Prevention in the United States: 
We've Come a Long Way! 

by 

Gerald Kotas 

Senior Environmental Scientist 
Office of Energy Efficiency and Renewable Energy 
U.S. Department of Energy 
Golden, Colorado 

Mr. Kotas is the Co-Director of the National Climate Wise Program. 

Pollution prevention, or source reduction, has been termed a strategy of first choice in addressing the highly 
complex environmental challenges of this decade. In fact, pollution prevention may be a very important step in 
our human understanding of how we collectively can and should fit into, and with, the Earth and its ecosystems. 
I have had the honor of working in the environmental field since the early 1970s and being part of EPA’s 
pollution prevention efforts when they were officially organized in 1988 and at DOE’s Office of Energy Effi¬ 
ciency and Renewable Energy since 1992. I have been very impressed with the public and private sector progress 
in both better understanding the complexity and the “interrelatedness” of environmental, economic, and social 
issues. I am also respectful of the significant challenges ahead, in terms of improving our understanding of both 
the interrelationships among all living things and the significant actions that must be taken in ALL sectors of 
our economy (industry, transportation, buildings, and energy generation) to continue our bridge-building to¬ 
ward a sustainable future. 

Where We’ve Been 

If we look back to our agrarian roots, our Native American brothers and sisters and our ancestors not only under¬ 
stood and appreciated their relationship with the earth and other living things, but even incorporated these connec¬ 
tions into their sacred traditions and belief systems. St. Francis of Assisi understood and lived his life according 
to principles of interconnectivity. Somehow, in the great technological strides of the industrial revolution, we lost 
sight of some of these basic understandings. The legacy of an extraction- and production- oriented economy has 
engendered a philosophy of taking, of limitless resources and limitless assimilative capacity of the environment. 
This “limited” thinking, coupled with the worldwide population explosion we are experiencing, has led to a new 
sense of crisis. 

Since the passage of the National Environmental Policy Act in 1969 and the major environmental statutes of the 
1970s and 1980s, our actions have been akin to triage in the medical field. The private and public sectors have 
made great strides in addressing the most pressing environmental problems in the air, water, land, and ground 
water. This is where we had to start. It was a treat- and- control set of strategies aimed primarily at toxic chemi¬ 
cals. By the mid to late 1980s, we were able to measure and “see” the improvements. The private sector also felt 
the economic hit of this approach. Compliance costs are currently estimated at over $150 billion per year and are 
expected to increase to $200 billion in the next five years. 

There were several shortcomings to this triage approach. By trying to solve environmental problems in one 
media (air, land, water) at a time, we have tended to shift the pollutants from one media to another, rather than 
rethinking the need for the substance in the first place or examining the processes for efficiency opportunities. 



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Chapter 8 - Guest Commentary 


This approach also often set up the thinking that economic and environmental progress were at odds with one 
another, rather than encouraging us to look for innovative solutions that deliver enhanced environmental results 
while truly helping a company’s bottom line. And finally, control technologies have real technological limits. 
When one examines the population estimates (mentioned earlier in this report), the resource intensity of our 
planetary footprints and the limits of even the most innovative technologies...’’you can’t get there from here.” 

Challenges and Opportunities 

Although we have collectively made significant progress in the past eight years in both policy and project imple¬ 
mentation, most of the implementation steps have been incremental. Paul Hawken states, “most educated people 
believe, or assume, that the major environmental threats faced by humankind can be fixed with relatively specific 
adjustments in technology and manufacturing practices.” With some of the correct policy now in place, a key 
part of our challenge is to better understand the barriers to more substantial change in private and public sector 
actions. We need to work together in new partnerships to develop and implement creative solutions that will lead 
to fundamental changes in our lifestyle; proximity to work; transport systems; buildings; selection, design and 
production of products; redesign of industrial processes and ecological collocations of industrial facilities; and 
more fundamental applications of energy efficiency and mainstreaming renewable energy generation sources. 

The deeper understanding of ecological prophets like Dr. Karl Henrik Robert (founder of the Natural Step), Paul 
Hawken, and Ernie Lowe needs to permeate our policy and our actions...not individual projects, but sustainable 
lifestyles. We need to reinforce the truly natural connections (not disconnections) between economic productiv¬ 
ity, sustainability and enhancement of environmental quality and protection of cultural resources. Interconnectivity 
is key to true sustainability. 

We must work together to forge even more lasting and creative public/private partnerships which result in 
technology “leaps,” facilitate more fundamental behavioral and lifestyle changes and help broker creative fi¬ 
nancing to facilitate implementation. Innovative international lending institutions like the World Bank have 
recognized the value (both economic and environmental value) of investing in eco-efficiency projects in less 
developed countries. One of the huge opportunities in the United States in the next decade will be the niche 
financing market for domestic eco-efficiency projects. The new unregulated and entrepreneurial utilities, banks, 
leasing companies, energy/environmental full-service companies and the insurance industry will all have a role 
in developing this niche market and helping private sector companies make these more fundamental changes 
with creative financing. 

In this new model, government moves into a role of research partner, broker of technical assistance and broker of 
financing assistance. I hope that this new role will be valued andsupported. If so, the next decade of work will 
be even more rewarding and fun than the last. 


252 




Appendix A 

Available Resources 


■ Publications/Directories 

■ National Services 


Regional Services 
























254 















Appendix A - Available Resources 


Publications/Directories 

A Citizen’s Guide to Achieving a Healthy Commu¬ 
nity, Economy & Environment 

Center for Compatible Economic Development 
7 East Market Street, Suite 210 
Leesburg, VA 20175 
Phone: (703) 779-1728 

Community-Based Environmental Protection: A 
Catalog of Initiatives and Tools for Community- 
Based Programs from the Office of Prevention, 
Pesticides and Toxic Substances (OPPTS) 

Available From: Two EPA hotlines: Toxics (202- 
554-1404) and Pesticides (800-858-7378) 

Description: This catalogue (currently under develop¬ 
ment with planned public availability in late summer 
1997) will describe tools, resources, and programs that 
relate to OPPTS’ extensive base of information on the 
characteristics and effects of pesticides and industrial 
chemicals. It will be available in at least two formats: 
as a printed manual and as a resource on the Internet, 
linked to other EPA information sites. 

EDF Letter 

Environmental Defense Fund 
257 Park Avenue South 
New York, NY 10010 
Phone: (212) 505-2100 

Description: Bimonthly newsletter for members that 
covers a wide range of environmental issues and EDF 
activities in recycling, waste reduction, and environ¬ 
mental protection. 


Environmental Planning for Small Communities - A 
Guide for Local Decision-Makers 

U.S. Environmental Protection Agency 
Document Number: EPA/625/R-94/009 
Phone: Available through EPA’s Office of Sustainable 
Ecosystems and Communities (202) 260-4002 
Description: This guide provides a general process for 
creating and implementing a community environmen¬ 
tal plan. A comprehensive environmental plan allows 
decision-makers to develop integrated approaches to 
protecting the environment and meeting their commu¬ 
nities’ needs. This approach will help the community 
prioritize solutions to environmental problems and 
develop a strategy for regulatory compliance. 

Guide to Pollution Prevention Funding 
Organizations 

Northwest Pollution Prevention Research Center 
1218 Third Avenue #1205 
Seattle, WA 98101 
Phone: (206) 223-1151 

Description: A directory of public and private organi¬ 
zations that fund pollution prevention research. 

Industrial Pollution Prevention Handbook 

Harry M. Freeman 

Published by McGraw-Hill, Inc., 1995 
ISBN 0-07-022148-0 

Linking Sustainable Community Activities to 
Pollution Prevention: A Sourcebook 

RAND 

1700 Main Street 
P.O. Box 2138 

Santa Monica, CA 90407-2138 
(310) 451-7002 
ISBN 0-8330-2500-7 

Making Peace with the Planet 

Barry Commoner 

Published by Pantheon Books, New York, 1990 
ISBN 0-394-56598-3 




255 


Appendix A - Available Resources 


Pollution Prevention: A Guide for Local Government 

Internation City/County Management Association 
777 North Capitol St., NE 
Washington, DC 20002 
Publication Number: ISBN 0-87326-073-2 
Description: This publication discusses the concept of 
pollution prevention. It addresses how to prevent 
pollution prevention in both government operations 
and institutions, and offers guidelines for manage¬ 
ment, planning, and implementation. 

Pollution Prevention: A Practical Guide for State 
and Local Government 

Edited by: David T. Wigglesworth 
Lewis Publishers, CRC Press, Inc. 

2000 Corporate Blvd., NW 
Boca Raton, FL 33431 
Publication Number: ISBN 0-87371-654-X 
Description: This publication focuses on current 
efforts to incorporate pollution prevention into the 
functions of state and local environmental agencies. It 
explains how to introduce pollution prevention 
methods into inspection programs, permitting proce¬ 
dures, enforcement actions, technical assistance, 
training, and voluntary initiatives. Topics covering the 
financing of pollution prevention efforts and factors 
contributing to their development are addressed. The 
book offers a wealth of practical information for state 
and government agency personnel, consultants, waste 
management personnel, and professionals in industry. 

Pollution Prevention Directory 

U.S. Environmental Protection Agency 
401 M Street, SW 
Washington, DC 20460 
Document Number: EPA/742/B-94/005 
Description: This directory contains brief descriptions 
and contacts for publicly sponsored pollution prevention 
resources available across the United States. The direc¬ 
tory includes: sources for pollution prevention information 
for the public in each state; resources and technical 
assistance programs for small- and medium-sized busi¬ 
nesses; university centers that are conducting pollution 
prevention research and training; selected federal agencies 
involved in pollution prevention; and additional resources 
available in the pollution prevention field. 


Pollution Prevention News 

U.S. Environmental Protection Agency (7409) 

401 M Street, SW 
Washington, DC 20460 

Phone: Available through the PPIC at (202) 260-1023 
Description: A free bimonthly newsletter on pollution 
prevention topics, including reports from EPA offices, 
people and places in the news, state programs, and 
calendar of conferences and events. 

Pollution Prevention Yellow Pages 

National Pollution Prevention Roundtable 
218 D Street, SE 
Washington, DC 20003 
Phone: (202) 543-7272 

Description: This directory lists and describes state 
and local pollution prevention programs. 

Preventing Industrial Toxic Hazards: A Guide for 
Communities 

INFORM, Inc. 

120 Wall Street 
New York, NY 10005 
Phone: (212) 361-2400 

Description: Leads community groups step-by-step 
through a process for encouraging local plants to 
reduce their use of toxic chemicals and their creation 
of toxic waste. By researching the plants and develop¬ 
ing a constructive dialog with plant managers, citizens 
can help businesses become better, cleaner neighbors. 

Preventing Pollution in Our Cities and Counties: A 
Compendium of Case Studies 

The National Association of Counties (NACo) 

440 First St., NW 
Washington, DC 20001 
Phone: (202) 393-6226 

Description: A joint publication of the National 
Association of County and City Health Officials, the 
National Association of Counties, the National 
Pollution Prevention Roundtable, the Municipal Waste 
Management Association, and the United States 
Conference of Mayors, this book documents successful 
examples of local pollution prevention activities. 


256 



Appendix A - Available Resources 


Prosperity Without Pollution: The Prevention 
Strategy for Industry and Consumers 

Joel S. Hirschhorn and Kirsten U. Oldenburg 
Published by Van Nostrand Reinhold, 1991 
ISBN 0-442-00225-4 

Study of Industry Motivation for Pollution Prevention 

U.S. Environmental Protection Agency 
Phone: (202) 260-1023 

Description: To be available in Summer 1997 from 
the Pollution Prevention Information Clearinghouse. 

Tackling Toxics in Everyday Products: A Directory 
of Organizations 

INFORM, Inc. 

120 Wall Street 
New York, NY 10005 
Phone: (212) 361-2400 

Description: Find out where to go for the information 
you need on hazards in products around your house, 
from paint to nail polish. Information on 250 organi¬ 
zations in the U.S. and abroad working on problems 
caused by the use and disposal of consumer and 
building products containing toxic chemicals. Cross 
references by products, chemicals, health issues, and 
geographical location make finding the right groups 
easy. 

Toxics Use Reduction Research Directory 

Toxics Use Reduction Institute 
University of Massachusetts at Lowell 
Lowell, MA 01854-2881 
Phone: (508) 934-3275 
Fax: (508) 453-2332 

Description: This guide provides background and 
contact information on government, private, univer¬ 
sity, and international organizations involved in toxics 
use reduction research. 


Toxics Watch 1995 
INFORM, Inc. 

120 Wall Street 
New York, NY 10005 
Phone: (212) 361-2400 

Description: Consolidates and examines data from the 
Toxics Release Inventory, RCRA, and numerous other 
sources to determine trends in the use of toxic chemi¬ 
cals in commerce, their presence in industrial waste, 
and their release to the environment. Looks at 
legislative developments in the field, new information 
on health effects, and the rise of the environmental 
justice movement. 


257 




Appendix A - Available Resources 


National Services 

Center for Hazardous Materials Research (CHMR) 

University of Pittsburgh Applied Research Center 

320 William Pitt Way 

Pittsburgh, PA 15238 

Phone: (412) 826-5321, x205 or x241 

Fax: (412) 826-5552 

Services: This center offers pollution prevention 
workshops for industrial representatives, consultants, 
engineering students, and regulatory personnel. Other 
features include on-site technical assistance, a technical 
assistance hotline, a quarterly newsletter, and industry- 
specific manuals and fact sheets. 

Center for Waste Reduction Technologies (CWRT) 

American Institute of Chemical Engineers 

345 East 47th Street 

New York, NY 10017 

Phone: (212) 705-6462 

Fax: (212) 752-3297 

Services: CWRT is an industry-driven, non-profit 
organization dedicated to sponsoring and developing 
new and innovative waste reduction technologies and 
methodologies. The Center’swork comprises targeted 
research, technology transfer, and enhanced education 
in a collaborative effort among industry, government, 
and academia. 

Chicago Board of Trade (CBOT) Recyclables 
Exchange 

141 W. Jackson Blvd. 

Chicago, IL 60604-2994 
Phone: (312) 341-7955 
Internet: http://www.cbot.com/recyclables 
Services: CBOT offers on-line (via the Internet) 
posting and trading of various grades of glass and 
paper as well as PET and HDPE plastics (other 
recyclable commodities will be added in the future); 
miscellaneous category available for trading other 
materials; offers testing, dispute resolution, and 
specifications for materials traded. 


Climate Wise Program 

U.S. Department of Energy 
Phone: (303) 275-4714 or (202) 586-2097 
Description: Participants are eligible for nationwide 
recognition for emission reduction achievements and 
pledge commitments. DOE and EPA help participants 
design and tailor a “custom fit” of Climate Change 
Action Plan programs for their companies and refer 
them to appropriate technical assistance centers to help 
reduce emissions still further. 

Common Sense Initiative 

U.S. Environmental Protection Agency (6103) 

401 M St., SW 
Washington, DC 20460 
Phone: (202) 260-8953 
Fax: (202) 260-9766 

Description: For the pilot phase of this project, EPA 
has selected six industries and has assembled a team of 
senior EPA staff, coupled with representatives of 
industry leaders, environmental organizations, state 
and local governments, labor unions, and other groups. 
Each team is developing a blueprint based on the 
following six principles for pollution control and 
prevention: (1) a comprehensive review of every EPA 
rule applicable to the industry, (2) pollution prevention 
as a guiding principle; (3) easier reporting procedures 
and wider public access to environmental information; 
(4) strong enforcement; (5) an improved permitting 
process; and (6) encouragement of new technology and 
innovation. 


258 









Appendix A - Available Resources 


Envirosense Network (E$) 

EPA Federal Facilities Enforcement Office 
U.S. Environmental Protection Agency (MC-2261) 

401 M St., SW 
Washington, DC 20460 
Phone: (202) 260-8859 
Internet: http://wastenot.inel.gov/envirosense 
Services: E$ is a free public interagency-supported 
that allows regulators, industry and the public to share 
information regarding: P2 and innovative technology; 
environmental enforcement and compliance assistance; 
laws, executive orders, regulations, and policies; and 
points of contact. E$ welcomes receipt of environmen¬ 
tal messages, information and data from any public or 
private person or organization. 

Green Business Resource Center 

Presented by The Green Business Letter and Environ¬ 
mental News Network 
Internet: http://www.enn.com/green.htm 
Services: The Center, to be opened in the Spring of 
1997, will be a one-stop information source for 
environmental managers and others in business, 
government, and institutions interested in learning 
how to integrate environmental thinking throughout 
their organizations. At the heart of the Center will be 
the Best Practices Database, which will allow users to 
search through hundreds of company environmental 
initiatives, including energy efficiency and renewables, 
solid waste reduction, pollution prevention/toxic 
reduction, and recycling and recycled procurement. 




Green Lights Program 

U.S. Environmental Protection Agency (6202-J) 

401 M St., SW 
Washington, DC 20460 
Phone: (202) 775-6650 
Fax: (202) 775-6680 or (202) 233-9659 
Services: EPA promotes energy efficient lighting by 
asking major institutions to sign a memorandum of 
understanding to commit to install energy-efficient 
lighting in 90% of its space nationwide over a 5-year 
period. The program helps identify financing re¬ 
sources for Partners, and provides a national lighting 
product information program with brand name informa¬ 
tion. Partners receive a computerized directory of 
financial and incentive programs offered by electric 
utilities, lighting managment companies, banks, and 
financing compnaies. Contact Regional offices or the 
Manager, Green Lights at the number above. 

National Center for Environmental Publications 
and Information (NCEPI) 

11029 Kenwood Road, Building 5 
Cincinnati, OH 45242 
Phone: (513) 891-6561 
Fax: (513) 891-6685 

Services: This center focuses on scientific/technical 
and public-oriented environmental information. 
Approximately 2,500 new titles are added annually to 
the NCEPI system database. Services are provided to 
federal, state, and local agencies, businesses, civic and 
environmental groups, academia, and the public. 

National Materials Exchange Network 

Pacific Material Exchange 

1522 N Washington Street, Suite 202 

Spokane, WA 99201-2454 

Phone: (509) 325-0551 

Fax: (509) 325-2086 

Services: The network is an electronic linking of over 
40 industrial waste exchanges across North America 
that allows users to locate available and wanted 
materials. The materials, which are organized into 17 
categories, include waste by-product, surplus, off-spec, 
over-stock, obsolete, and damaged materials. 


259 




Appendix A - Available Resources 


National Technical Information Service (NTIS) 

5285 Port Royal Road 
Springfield, VA 22161 
Phone: (703) 487-4650 

Description: NTIS is the central source for the public 
sale of U.S. Government-sponsored research, develop¬ 
ment, and engineering reports and federally generated 
machine-processible data files. It contains various 
reports including those on: air pollution, acid rain, 
water pollution, marine pollution, land use planning, 
solar energy, solid wastes, and radiation monitoring. 

Pollution Prevention Homepage 

U.S. Environmental Protection Agency 
Office of Pollution Prevention and Toxics 
Internet: http://www.epa.gov/opptintr/opptp2.htm 
Services: This web site contains information on EPA 
pollution prevention grants and initiatives. It also 
provides links to numerous EPA pollution prevention 
programs (e.g., Enviro$ense and Design for the 
Environment). Several pollution prevention publica¬ 
tions are also available through this web site. 

Pollution Prevention Information Clearinghouse 
(PPIC) 

U.S. Environmental Protection Agency (3404) 

401 M Street, SW 
Washington, DC 20460 
Phone: (202) 260-1023 
Fax: (202) 260-0178 
E-mail: ppic@epamail.epa.gov 
Services: PPIC is a distribution center for non-regula- 
tory documents emanating from the EPA Office of 
Pollution Prevention and Toxics (OPPT) and various 
other EPA programs. PPIC also maintains a telephone 
hotline for document orders and to refer callers to 
other information resources. PPIC maintains a 
collection of documents relating to pollution preven¬ 
tion , waste minimization, and alternative technolo¬ 
gies. The collection is available for browsing in the 
EPA Headquarters Library and through EPA’s Online 
Library System. 


Pollution Prevention Incentives for States (PPIS) 

Office of Pollution Prevention and Toxics 
U.S. Environmental Protection Agency (7409) 

401 MSt., SW 
Washington, DC 20460 
Phone: (202) 260-2237 
Fax: (202) 260-0178 

Services: PPIS builds and supports state pollution 
prevention capabilities. It funds the institutionaliza¬ 
tion of multimedia pollution prevention as an environ¬ 
mental management priority. PPIS grants fund other 
pollution prevention activities such as providing direct 
technical assistance to businesses, collecting and 
analyzing data, conducting outreach and funding 
demonstration projects for testing and evaluating 
innovative pollution prevention approaches and 
methodologies. States and federally-recognized tribes 
are eligible for awards. 

33/50 Program 

Office of Pollution Prevention and Toxics 
U.S. Environmental Protection Agency (7408) 

401 M St., SW 
Washington, DC 20460 
Phone: (202) 260-6907 
Fax: (202) 260-2219 

Services: EPA’s volunatry pollution prevention 
program has identified 17 chemicals that participating 
firms agree to reduce releases by 33% in 1992 and 
50% by 1995. Industries may achieve these goals 
through their own initiatives. Goals are measured 
against TRI reporting for 1988. 

Toxics Release Inventory (TRI) 

U.S. Environmental Protection Agency 

401 M St., SW 

Washington, DC 20460 

Phone: (202) 260-1512 

User Support: (202) 260-1531 

Description: TRI is a database of toxic chemicals 

maintained by EPA under mandate of Section 313 of 

the Emergency Planning and Community Right-to- 

Know Act. Manufacturing facilities are required to 

report on releases of toxic chemicals to air, water, and 

land and off-site transfers. The TRI is available on CD- 

ROM, microfiche diskette, reports, directors, and on the 

Internet. 


260 


Appendix A - Available Resources 


WasteWi$e Program 

Office of Solid Waste 

U.S. Environmental Protection Agency (5306) 

401 M St., SW 

Washington, DC 20460 

Phone: (800) 372-9473 or 1-800-EPAWISE 

Fax: (202) 260-4196 

Services: EPA’s partnerships with business promote 
reductions in municipal solid waste. WasteWi$e 
companies prevent waste at the source, collect materi¬ 
als for recycling, and increase the recycled content of 
products they buy or manufacture. 

Water Alliance for Voluntary Efficiency (WAVE) 

U.S. Environmental Protection Agency (4202) 

401 M St., SW 
Washington, DC 20460 
Phone: (202) 260-7288 
Fax: (202) 260-1827 

Services: This voluntary partnership promotes water 
efficiency in commercial businesses and institutions 
through the use of low-flow bathroom fixtures, water- 
efficient laundry and kitchen equipment, efficient 
cooling water maintenance and water-efficient land¬ 
scaping and irrigation. Information is shared among 
utilities, municipalities, equipment manufacturers, water 
service companies, and others. 


261 


Appendix A - Available Resources 





Regional Services 


These are only a sampling of services available across 
the country. Contact EPA’s Regional Pollution 
Prevention Coordinator for more information. 

EPA Region 1 (CT, MA, ME, NH, RI, VT) 

Region I P2 Coordinator 

Abby Swaine/Mark Mahoney 

U.S. Environmental Protection Agency 

JFK Federal Building, Rm 2003 

Boston, MA 02203 

Phone: (617) 565-4523 

Fax:(617)565-3346 

Northeast Waste Management Officials’ Association 
(NEWMOA) 

129 Portland St. 

Boston, MA 02114 
Phone: (617) 367-8558 
Fax: (617) 376-0449 

Services: NEWMOA operates a clearinghouse of 
information on P2, conducts training sessions for state 
officials and industry representatives on source 
reduction, coordinates an interstate roundtable of state 
pollution prevention programs, and researches source 
reduction strategies. A quarterly newsletter is also 
published. 

Toxics Use Reduction Institute 

University of Massachusetts - Lowell 
One University Avenue 
Lowell, MA 01854 
Phone: (508) 934-3275 
Fax: (508) 934-3050 

Services: The institute promotes reduction in the use 
of toxic chemicals or the generation of toxic 
byproducts in industry. Programs include workshops 
and conferences on topics such as material substitu¬ 
tion, closed loop processes, and toxic use audits. The 
institute also maintains a library of toxics use reduction 
information as well as a surface cleaning laboratory. 


EPA Reeion 2 (NJ, NY, Puerto Rico, Virgin Islands) 

Region II P2 Coordinator 

Janet Sapadin 

U.S. Environmental Protection Agency 

290 Broadway 

New York, NY 10007 

Phone: (212) 637-3584 

Fax: (212) 637-5045 

Center for Waste Reduction Technologies (CWRT) 

American Institute of Chemical Engineers 

345 East 47th Street 

New York, NY 10017 

Phone: (212) 705-7462 

Fax: (212) 752-3297 

Services: CWRT sponsors and develop new and 
innovative waste reduction technologies and transfers 
this information to industry. The Center is sponsored 
by major manufacturing and chemical/petroleum 
companies. Technology transfer activities include 
publications, and the development of broad, 
interlinked databases for identification and application 
of waste reduction technologies. 

EPA Region 3 (DC, DE, MD, PA, VA, WV) 

Region III P2 Coordinator 

Jeff Burke 

U.S. Environmental Protection Agency 
841 Chestnut St. 

Philadelphia, PA 19107 
Phone: (215) 597-0765 
Fax: (215) 597-7906 

Center for Hazardous Materials Research 

320 William Pitt Way 
Pittsburgh, PA 15238 
Phone: (412) 826-5320 
Fax: (412) 826-5552 


262 





Appendix A - Available Resources 


Great Lakes and Mid-Atlantic Hazardous Substance 
Research Center 

Department of Civil Engineering 
Howard University 
Washington, DC 20059 
Phone: (202) 806-6570 

Services: The Center, funded by EPA, focuses on 
Regions III and IV. Research is conducted on hazard¬ 
ous substances. The Center is developing materials for 
a hazardous waste workshop and videotapes on waste 
minimization information and training. 

Metro Washington Council of Governments 

Department of Environmental Programs 
777 North Capitol St., NE, Suite 300 
Washington, DC 20002 
Phone: (202) 962-3355 
Fax: (202) 962-3201 

Pennsylvania Technical Assistance Program 

Penn State University 
117 Tech Center 
University Park, PA 16802 
Phone: (814) 865-0427 
Fax: (814) 865-5909 

Services: PENNTAP is an industrial technology 
extension service which provides scientific and 
technological assistance to business and industry 
throughout Pennsylvania to help improve their 
competitiveness. PENNTAP focuses on helping small 
size businesses that normally do not have the in-house 
expertise or time to resolve specific technical questions 
or problems. 


Solid Waste Association of North America (SWANA) 

P.O. Box 7219 

Silver Spring, MD 20910 

Phone: (800) 677-9424 (SWAP) 

Phone: (301) 585-2898 (SWANA) 

Fax: (301) 589-7068 

Services: SWANA operates the Solid Waste Assis¬ 
tance Program (SWAP) and the Peer Match Program. 
SWAP is a technical information hotline designed to 
collect and distribute materials and provide assistance 
to all interested parties on solid waste management. 

The Peer Match Program aids state and local govern¬ 
ments by connecting knowledgeable municipal solid 
waste professionals with communities in need of 
assistance. 

EPA Region 4 (AL, GA, FL, KY, MS, NC, SC, TN) 

Region IV P2 Coordinator 

Dan Ahern 

U.S. Environmental Protection Agency 
345 Courtland St., NE 
Atlanta, GA 30365 
Phone: (404) 347-3555 
Fax: (404) 347-1043 

Alabama Waste Reduction and Technology Transfer 
(WRATT) Foundation 

Box 1010 

Muscle Shoals, AL 35662 
Phone: (205) 386-2807 
Fax: (205) 386-2674 
Services: WRATT offers free, voluntary, 
nonregulatory, confidential waste reduction assess¬ 
ments for public and private entities. WRATT runs a 
speakers bureau, provides waste reduction assessor 
training, and offers workshops and conferences on 
waste reduction for businesses. 


263 



Appendix A - Available Resources 


Mississippi Technical Assistance Program 
(MISSTAP) 

P.O. Box 9595 
Mississippi State, MS 39762 
Phone: (601) 325-8454 
Fax: (601) 325-8616 

Services: Monthly newsletter lists materials available 
and wanted. 

Tennessee Valley Authority 

Industrial Waste Reduction 
400 West Summit Hill Drive 
Knoxville, TN 37902 
Phone: (423) 632-8489 
Fax: (423) 632-3616 

Services: The Industrial Waste Reduction team focuses 
on helping industries reduce waste and save money by 
making their industrial processes more efficient. The 
services include: process efficiency, in-plant evalua¬ 
tions, waste management consulting, and training. 

Waste Reduction Resource Center 

3825 Barrett Drive, Suite 104 
Raleigh, NC 27609 
Phone: (800) 476-8686 
Fax: (919)571-4135 

Services: Helps coordinate P2 with other agencies, 
promotes economic development, helps deploy new 
technology, and provides direct assistance to reduce 
pollution generation and business compliance. 

EPA Region 5 (IL, IN, MI, MN, OH, WI) 

Region V P2 Coordinator 

Cathy Allen 

U.S. Environmental Protection Agency 
77 W. Jackson Blvd. 

Chicago, II 60604 
Phone: (312) 886-0180 
Fax: (312) 886-0957 


Center for Environmental and Regulatory Informa¬ 
tion Systems (CERIS) 

Purdue University 
1231 Cumberland Ave., Suite A 
West Lafayette, IN 47906 
Phone: (317) 494-6616 
Fax: (317) 494-9727 

Center for Neighborhood Technology 

2125 North Avenue 
Chicago, IL 60647 
Phone: (312) 278-4800 

Services: Center provide assistance on pollution 
prevention, energy efficiency, waste reduction and 
material substitution for job-shop proprietors who need 
help complying with environmental regulations. A 
magazine, Neighborhood Works, is published monthly. 

Illinois Hazardous Waste Research and Information 
Center (HWRIC) 

One East Hazelwood Dr. 

Champaign, IL 61820 
Phone: (217) 333-8940 
Fax: (217)333-8944 

Lake Michigan Federation 

59 E. Van Buren, #2215 
Chicago, IL 60605 
Phone:(312) 939-0838 
Fax: (312) 939-2708 

Services: The Lake Michigan Federation is involved in 
many programs which focus on: promoting water 
quality that supports a healthy ecosystem; habitat and 
wetland preservation or restoration; sustainable 
shoreline and lake uses in the public interest; and 
public access to the lake and shoreline. 

EPA Region 6 (AR, LA, NM, OK, TX) 


Region VI P2 Coordinator 

Robert Lawrence/Linda Thompson 

U.S. Environmental Protection Agency 

1445 Ross Ave., Suite 1200 

MC 6EN-XP 

Dallas, TX 75202 

Phone: (214) 665-6444 or 6568 

Fax: (214) 666-7466 


264 





Appendix A - Available Resources 


Arkansas Industrial Development Commission 
(AIDC) 

1 Capitol Mall, Room 4B215 
Little Rock, AR 72201 
Phone: (501) 682-7325 
Fax: (501) 682-2703 

Services: Arkansas Manufacturing Exchange publishes 
a catalog bimonthly and distributes it to 3,500 manu¬ 
facturers; accepts most materials; operates 
ScrapMatch, a market identifier for various materials. 

Gulf Coast Hazardous Substance Research Center 

Lamar University 
P.O. Box 10613 
Beaumont, TX 77710 
Phone: (409) 880-8707 
Fax: (409) 880-2397 

Services: This consortium of eight universities 
conducts research to aid more effective hazardous 
substance response and waste management. The Center 
focuses on waste minimization and alternative technol¬ 
ogy development with an emphasis on the petrochemi¬ 
cal and microelectronic industries. 

EPA Region 7 (IA, KS, MO, NE) 

Region VII P2 Coordinator 

Steve Wurtz 

U.S. Environmental Protection Agency 
726 Minnesota Ave. 

Kansas City, KS 66101 
Phone: (913) 551-7315 
Fax: (913) 551-7065 

Great Plains-Rocky Mountain Hazardous Substance 
Research Center 

Kansas State University 
101 Ward Hall 
Manhattan, KS 66506 
Phone: (913) 532-4313 
Fax: (913) 532-5985 


EPA Region 8 (CO, MT, ND, SD, UT, WY) 

Region VIII P2 Coordinator 

Sharon Riegel 

U.S. Environmental Protection Agency 

999 18th St., Suite 500 

MC 8PM-SiPO 

Denver, CO 80202-2466 

Phone: (303) 293-1471 

Fax: (303) 391-6216 

Colorado Pollution Prevention Partnership 

1099 18th Street, Suite 2100 
Denver, CO 80202 
Phone: (303) 294-1200 
Fax: (303) 294-1234 

Services: A partnership of government, business, and 
public interest groups organized to develop and 
promote waste minimization and pollution prevention to 
industry. One project focused on voluntary reduction of 
solvent. 

Energy and Environmental Research Center 

Center of Excellence for Toxic Metal Emissions 
University of North Dakota 
15 North 23rd St. 

University Station, Box 8213 
Grand Forks, ND 58202 
Phone: (701) 777-5131 
Fax: (701) 777-5181 

Services: The Center evaluates and characterizes the 
earth’s resources, conducts research and develops 
innovative technologies to extract and use the re¬ 
sources in an environmentally-acceptable manner, and 
uses natural resources to dispose of wastes. 

EPA Region 9 (AZ, CA, HI, NV) 

Region IX P2 Coordinator 

Eileen Sheehan/Bill Wilson 

U.S. Environmental Protection Agency 

75 Hawthorne St. 

San Francisco, CA 94105 
Phone: (415) 744-2190 
Fax: (415)744-1796 


265 





Appendix A - Available Resources 


California Department of Toxic Substances Control 

400 P Street 
P.O. Box 806 
Sacramento, CA 95812 
Phone: (916) 322-3670 

Services: Implements the Hazardous Waste Reduction 
Grant Program, which provides grants for the research 
and development of hazardous waste reduction, 
recycling, and treatment technologies. It also main¬ 
tains a Technology Clearinghouse and technology 
transfer outreach programs, and participates in the 
Paint Recycling Task Force. 

EPA Region 10 (AK, ID, OR, WA) 

Region X P2 Coordinator 

Carolyn Gangmark/Robin Meeker 
U.S. Environmental Protection Agency 
1200 Sixth Ave. 

Seattle, WA 98101 
Phone: (206) 553-4072 
Fax: (206) 553-6647 

Pacific Northwest Pollution Prevention Research 
Center 

1326 Fifth Ave., Suite 650 
Seattle, WA 98101 
Phone: (206) 223-1151 
Fax: (206) 223-1165 

Services: The Center is a public-private partnership 
formed to identify opportunities and overcome ob¬ 
stacles to pollution prevention. Activities include 
identifying research and project needs, facilitating 
transfer of pollution prevention information, and 
providing research support. The Center acts as a 
referral service and is establishing an Industrial Liaison 
Project to transfer the results of nonproprietary pollu¬ 
tion prevention research from large to small compa¬ 
nies. A bimonthly newsletter is published and the 
Center hosts seminars, and maintains several data¬ 
bases to help technical assistance programs. 


266 



Appendix B 

Pollution Prevention Act 
of 1990 



Appendix B - Pollution Prevention Act of 1990 











268 















Appendix B - Pollution Prevention Act of 1990 


The Pollution Prevention Act of 1990 


Public Law 101-508, 

Title 6, 104 STAT. 1388 (1990). 

This Act became law on October 26, 1990 upon being signed by the President. 

SEC. 6601. SHORT TITLE 

This subtitle may be cited as the “Pollution Prevention Act of 1990”. 

SEC. 6602. FINDINGS AND POLICY 

a. FINDINGS - The Congress finds that: 

1. The United States of America annually produces millions of tons pollution and 
spends tens of billions of dollars per year controlling this pollution. 

2. There are significant opportunities for industry to reduce or prevent pollution at 
the source through cost-effective changes in production, operation, and raw materials 
use. Such changes offer industry substantial savings in reduced raw material, pollution 
control, and liability costs as well as help protect the environment and reduce risks to 
worker health and safety. 

3. The opportunities for source reduction are often not realized because existing 
regulations, and the industrial resources they require for compliance, focus upon treat¬ 
ment and disposal, rather than source reduction; existing regulations do not emphasize 
multi-media management of pollution; and businesses need information and technical 
assistance to overcome institutional barriers to the adoption of source reduction prac¬ 
tices. 

4. Source reduction is fundamentally different and more desirable than waste man¬ 
agement and pollution control. The Environmental Protection Agency needs to address 
the historical lack of attention of source reduction. 

5. As a first step in preventing pollution through source reduction, the Environmen¬ 
tal Protection Agency must establish a source reduction program which collects and 
disseminates information, provides financial assistance to States, and implements the 
other activities provided for in this subtitle. 

b. POLICY - The Congress hereby declares it to be the national policy of the United 
States that pollution should be prevented or reduced at the source whenever feasible pollu¬ 
tion that cannot be prevented should be recycled in an environmentally safe manner when¬ 
ever feasible; pollution that cannot be prevented or recycled should be treated in an environ¬ 
mentally safe manner whenever feasible; and disposal or other release into the environment 
should be employed only as a last resort and should be conducted in an environmentally safe 
manner. 

SEC. 6603. DEFINITIONS 

For purposes of this subtitle- 

1. The term “Administrator” means the Administrator of the Environmental Protec¬ 
tion Agency. 

2. The term “Agency” means the Environmental Protection Agency. 

3. The term “toxic chemical” means any substance on the list described in section 
313(c) of the Superfund Amendments and Reauthorization Act of 1986. 

4. The term “release” has the same meaning as provided by section 329(8) of the 
Superfund Amendments and Reauthorization Act of 1986. 

A. The term “source reduction” means any practice which- 


42 USC 13101 


42 USC 13102 


269 


Appendix B - Pollution Prevention Act of 1990 


i. reduces the amount of any hazardous substance, pollutant, or contaminant 
entering any waste stream or otherwise released into the environment (including 
fugitive emissions) prior to recycling, treatment, or disposal; and 

ii. reduces the hazards to public health and the environment associated with 
the release of such substances, pollutants, or contaminants. 

The term includes equipment or technology modifications, process or procedure 
modifications, reformulation or redesign of products, substitution of raw materials, 
and improvements in housekeeping, maintenance, training, or inventory control. 

B. The term “source reduction” does not include any practice which alters the physi¬ 
cal, chemical, or biological characteristics or the volume of a hazardous substance, pol¬ 
lutant, or contaminant through a process or activity which itself is not integral to and 
necessary for the production of a product or the providing of a service. 

5. The term “multi-media” means water, air, and land. 

6. The term “SIC codes” refers to the 2-digit code numbers used for classification of 
economic activity in the Standard Industrial Classification Manual. 

42 USC 13103 SEC. 6604. EPA ACTIVITIES 

a. AUTHORITIES - The Administrator shall establish in the Agency an office to carry out 
the functions of the Administrator under this subtitle. The office shall be independent of the 
Agency’s single-medium program offices but shall have the authority to review and advise 
such offices on their activities to promote a multi media approach to source reduction. The 
office shall be under the direction of such officer of the Agency as the Administrator shall 
designate. 

b. FUNCTIONS - The Administrator shall develop and implement a strategy to promote 
source reduction. As part of the strategy, the Administrator shall- 

1. establish standard methods of measurement of source reduction; 

2. ensure that the Agency considers the effect of its existing and proposed programs 
on source reduction efforts and shall review regulations of the Agency prior and subse¬ 
quent to their proposal to determine their effect on source reduction; 

3. coordinate source reduction activities in each Agency Office and coordinate with 
appropriate offices to promote source reduction practices in other Federal agencies, and 
generic research and development on techniques and processes which have broad appli¬ 
cability; 

4. develop improved methods of coordinating, streamlining and assuring public ac¬ 
cess to data collected under Federal environmental statutes; 

5. facilitate the adoption of source reduction techniques by businesses. This strat¬ 
egy shall include the use of the Source Reduction Clearinghouse and State matching 
grants provided in this subtitle to foster the exchange of information regarding source 
reduction techniques, the dissemination of such information to businesses, and the pro¬ 
vision of technical assistance to businesses. The strategy shall also consider the capa¬ 
bilities of various businesses to make use of source reduction techniques; 

6. identify, where appropriate, measurable goals which reflect the policy of this 
subtitle, the tasks necessary to achieve the goals, dates at which the principal tasks are to 
be accomplished, required resources, organizational responsibilities, and the means by 
which progress in meeting the goals will be measured; 

7. establish an advisory panel of technical experts comprised of representatives 
from industry, the States, and public interest groups, to advise the Administrator on 
ways to improve collection and dissemination of data; 


270 









Appendix B - Pollution Prevention Act of 1990 


8. establish a training program on source reduction opportunities, including work¬ 
shops and guidance documents, for State and Federal permit issuance, enforcement, and 
inspection officials working within all agency program offices; 

9. identify and make recommendations to Congress to eliminate barriers to source 
reduction including the use of incentives and disincentives; 

10. identify opportunities to use Federal procurement to encourage source reduc¬ 
tion; 

11. develop, test and disseminate model source reduction auditing procedures de¬ 
signed to highlight source reduction opportunities; and 

12. establish an annual award program to recognize a company or companies which 
operate outstanding or innovative source reduction programs. 

SEC. 6605. GRANTS TO STATES FOR STATE TECHNICAL ASSISTANCE 
PROGRAMS 

a. GENERAL AUTHORITY - The Administrator shall make matching grants to States for 
programs to promote the use of source reduction techniques by businesses. 

b. CRITERIA - When evaluating the request for grants under this section, the Administra¬ 
tor shall consider, among other things, whether the proposed State program would accom¬ 
plish the following: 

1. Make specific technical assistance available to businesses seeking information 
about source reduction opportunities, including funding for experts to provide onsite 
technical advice to business seeking assistance and to assist in the development of source 
reduction plans. 

2. Target assistance to businesses for whom lack of information is an impediment to 
source reduction. 

3. Provide training in source reduction techniques. Such training may be provided 
through local engineering schools or any other appropriate means. 

c. MATCHING FUNDS - Federal funds used in any State program under this section shall 
provide no more than 50 per centum of the funds made available to a State in each year of that 
State’s participation in the program. 

d. EFFECTIVENESS - The Administrator shall establish appropriate means for measuring 
the effectiveness of the State grants made under this section in promoting the use of source 
reduction techniques by businesses. 

e. INFORMATION - States receiving grants under this section shall make information 
generated under the grants available to the Administrator. 

SEC. 6606. SOURCE REDUCTION CLEARINGHOUSE 

a. AUTHORITY - The Administrator shall establish a Source Reduction Clearinghouse 
to compile information including a computer data base which contains information on man¬ 
agement, technical, and operational approaches to source reduction. The Administrator shall 
use the clearinghouse to- 

1. serve as a center for source reduction technology transfer; 

2. mount active outreach and education programs by the States to further the adop¬ 
tion of source reduction technologies; and 

3. collect and compile information reported by States receiving grants under section 
6605 on the operation and success of State source reduction programs. 

b. PUBLIC AVAILABILITY - The Administrator shall make available to the public such 
information on source reduction as is gathered pursuant to this subtitle and such other perti¬ 
nent information and analysis regarding source reduction as may be available to the Admin¬ 
istrator. The data base shall permit entry and retrieval of information to any person. 


42 USC 13104 


42 USC 13105 


271 


Appendix B - Pollution Prevention Act of 1990 


42 USC 13106 


SEC. 6607. SOURCE REDUCTION AND RECYCLING DATA COLLECTION 

a. REPORTING REQUIREMENTS - Each owner or operator of a facility required to file 
an annual toxic chemical release form under section 313 of the Superfund Amendments and 
Reauthorization Act of 1986 (“SARA”) for any toxic chemical source reduction and recycling 
report for the proceeding calendar year. The toxic chemical source reduction and recycling 
report shall cover each toxic chemical required to be reported in the annual toxic chemical 
release form filed by the owner or operator under section 313(c) of that Act. This section shall 
take effect with the annual report filed under section 313 for the first full calendar year 
beginning after the enactment of this subtitle. 

b. ITEMS INCLUDED IN REPORT - The toxic chemical source reduction and recycling 
report required under subsection (a) shall set forth each of the following on a facility-by¬ 
facility basis for each toxic chemical: 

1. The quantity of the chemical entering any waste stream (or otherwise released 
into the environment) prior to recycling, treatment, or disposal during the calendar year 
for which the report is filed and the percentage change from the previous year. The 
quantity reported shall not include any amount reported under paragraph (7). When ac¬ 
tual measurements of the quantity of a toxic chemical entering the waste streams are not 
readily available, reasonable estimates should be made on best engineering judgment. 

2. The amount of the chemical from the facility which is recycled (at the facility or 
elsewhere) during such calendar year, the percentage change from the previous year, and 
the process of recycling used. 

3. The source reduction practices used with respect to that chemical during such 
year at the facility. Such practices shall be reported in accordance with the following 
categories unless the Administrator finds other categories to be more appropriate. 

A. Equipment, technology, process, or procedure modifications. 

B. Reformulation or redesign of products. 

C. Substitution of raw materials. 

D. Improvement in management, training, inventory control, materials han¬ 
dling, or other general operational phases of industrial facilities. 

4. The amount expected to be reported under paragraphs (1) and (2) for the two 
calendar years immediately following the calendar year for which the report is filed. 
Such amount shall be expressed as a percentage change from the amount reported in 
paragraphs (1) and (2). 

5. A ratio of production in the production year to production in the previous year. 
The ratio should be calculated to most closely reflect all activities involving the toxic 
chemical. In specific industrial classificationssubj ect to this section, where a feedstock 
or some varable other than production is the primary influence on waste characteristics 
or volumes, the report may provide an index based on that primary variable for each 
toxic chemical. The Administrator is encouraged to develop production indexes to ac¬ 
commodate individual industries for use on a voluntary basis. 

6. The techniques which were used to identify source reduction opportunities. Tech¬ 
niques listed should include, but are not limited to, employee recommendations, exter¬ 
nal and internal audits, participating team management, and material balance audits. 
Each type of source reduction listed under paragraph (3) should be associated with the 
techniques or multiples of techniques used to identify the source reduction technique. 

7. The amount of any toxic chemical released into the environment which resulted 
from a castatrophic event, remedial action, or other one-time event, and is not associated 
with production processes during the reporting year. 

8. The amount of the chemical from the facility which is treated (at the facility or 
elsewhere) during such calendar year and the percentage change from the previous year. 
For the first year of reporting under this subsection, comparison with the previous year is 
required only to the extent such information is available. 


272 


Appendix B - Pollution Prevention Act of 1990 


c. SARA PROVISIONS - The provisions of sections 322, 325(c), and 326 of the Superfund 
Amendments and Reauthorization Act of 1986 shall apply to the reporting requirements of 
this section in the same manner as to the reports required under section 313 of that Act. The 
Administrator may modify the form required for purposes of reporting information under 
section 313 of that Act to the extent he deems necessary to include the additional information 
required under this section. 

d. ADDITIONAL OPTIONAL INFORMATION - Any person filing a report under this 
section for any year may include with the report additional information regarding source 
reduction, recycling, and other pollution control techniques in earlier years. 

e. AVAILABILITY OF DATA - Subject to section 322 of the Superfund Amendments and 
Reauthorization Act of 1986, the Administrator shall make data collected under this section 
publicly available in the same manner as the data collected under section 313 of the Superfund 
Amendments and Reauthorization Act of 1986. 

SEC. 6608. EPA REPORT 42 USC 13107 

a. BIENNIAL REPORTS - The Administrator shall provide Congress with a report within 
eighteen months after enactment of this subtitle and biennially thereafter, containing a de¬ 
tailed description of the actions taken to implement the strategy to promote source reduction 
developed under section 4(b) and the results of such actions. The report shall include an 
assessment of the effectiveness of the clearinghouse and grant program established under this 
subtitle in promoting the goals of the strategy, and shall evaluate data gaps and data duplica¬ 
tion with respect to data collected under Federal environmental statutes. 

b. SUBSEQUENT REPORTS - Each biennial report submitted under subsection (a) after 
the first report shall contain each of the following: 

1. An analysis of the data collected under section 6607 on an industry-by-industry 
basis for not less than five SIC codes or other categories as the Administrator deems 
appropriate. The analysis shall begin with those SIC codes or other categories of facili¬ 
ties which generate the largest quantities of toxic chemical waste. The analysis shall 
include an evaluation of trends in source reduction by industry, firm size, production, or 
other useful means. Each such subsequent report shall cover five SIC codes or other 
categories which were not covered in a prior report until all SIC codes or other catego¬ 
ries have been covered. 

2. An analysis of the usefulness and validity of the data collected under section 
6607 for measuring trends in source reduction and the adoption of source reduction by 
business. 

3. Identification of regulatory and nonregulatory barriers to source reduction, and of 
opportunities for using existing regulatory programs, and incentives and disincentives to 
promote and assist source reduction. 

4. Identification of industries and pollutants that require priority assistance in multi- 
media source reduction. 

5. Recommendations as to incentives needed to encourage investment and research and 
development in source reduction. 

6. Identification of opportunities and development of priorities for research and 
development in source reduction methods and techniques. 

7. An evaluation of the cost and technical feasibility, by industry and processes, of 
source reduction opportunities and current activities and an identification of any indus¬ 
tries for which there are significant barriers to source reduction with an analysis of the 
basis of this identification. 

8. An evaluation of methods coordinating, streamlining, and improving public ac¬ 
cess to data collected under Federal environmental statutes. 

9. An evaluation of data gaps and data duplication with respect to data collected under 
Federal environmental statutes. 


273 


Appendix B 


42 USC 13108 


42 USC 13109 


Pollution Prevention Act of 1990 


In the report following the first biennial report provided for under this subsection, para¬ 
graphs (3) through (9) may be included at the discretion of the Administrator. 

SEC. 6609. SAVINGS PROVISIONS 

a. Nothing in this subtitle shall be construed to modify or interfere with the implementa¬ 
tion of title III of the Superfund Amendments and Reauthorization Act of 1986. 

b. Nothing contained in this subtitle shall be construed, interpreted or applied to supplant, 
displace, preempt or otherwise diminish the responsibilities and liabilities under other State 
or Federal law, whether statutory or common. 

SEC. 6610. AUTHORIZATION OF APPROPRIATIONS 

There is authorized to be appropriated to the Administrator $8,000,000 for each of the 
fiscal years 1991, 1992 and 1993 for functions carried out under this subtitle (other than State 
grants), and $8,000,000 for each of the fiscal years 1991, 1992 and 1993, for grant programs 
to States issued pursuant to section 6605. 


274 






Appendix C 

Pollution Prevention: EPA 
Statement of Def inition 



Appendix C - Pollution Prevention: EPA Statement of Definition 


276 


Appendix C Pollution Prevention: EPA Statement of Definition 


Pollution Prevention: EPA Statement of 
Definition 

(pursuant to the Pollution Prevention Act of 1990 
and the Pollution Prevention Strategy) 


Under Section 6602(b) of the Pollution Prevention Act of 1990, Congress established 
a national policy that: 

■ pollution should be prevented or reduced at the source whenever feasible; 

■ pollution that cannot be prevented should be recycled in an environmentally 
safe manner whenever feasible; 


■ pollution that cannot be prevented or recycled should be treated in an environ¬ 
mentally safe manner whenever feasible; and 


disposal or other release into the environment should be employed only as a 
last resort and should be conducted in an environmentally safe manner. 


Pollution prevention means “source reduction,” as defined under the Pollution Pre¬ 
vention Act, and other practices that reduce or eliminate the creation of pollutants 
through: 


— increased efficiency in the use of raw materials, energy, water, or other 
resources, or 


— protection of natural resources by conservation. 

The Pollution Prevention Act defines “source reduction” to mean any practice which: 

— reduces the amount of any hazardous substance, pollutant, or contaminant 
entering any waste stream or otherwise released into the environment 
(including fugitive emissions) prior to recycling, treatment, or disposal; 
and 


— reduces the hazards to public health and the environment associated with 
the release of such substances, pollutants, or contaminants. 

The term includes: equipment or technology modifications, process or procedure 
modifications, reformulation or redesign of products, substitution of raw materials, 
and improvements in housekeeping, maintenance, training, or inventory control. 

Under the Pollution Prevention Act, recycling, energy recovery, treatment, and dis¬ 
posal are not included within the definition of pollution prevention. Some practices 
commonly described as “in-process recycling” may qualify as pollution prevention. 
Recycling that is conducted in an environmentally sound manner shares many of the 
advantages of prevention — it can reduce the need for treatment or disposal, and 
conserve energy and resources. 


277 



Appendix C - Pollution Prevention: EPA Statement of Definition 


Pollution prevention approaches can be applied to all pollution-generating activity, 
including those found in the energy, agriculture, federal, consumer, as well as indus¬ 
trial sectors. The impairment of wetlands, ground water sources, and other critical 
resources constitutes pollution, and prevention practices may be essential for pre¬ 
serving these resources. These practices may include conservation techniques and 
changes in management practices to prevent harm to sensitive ecosystems. Pollution 
prevention does not include practices that create new risks or concerns. 

In the agricultural sector, pollution prevention approaches include: 

— reducing the use of water and chemical inputs; 

— adoption of less environmentally harmful pesticides or cultivation of crop 
strains with natural resistance to pests; and 

— protection of sensitive areas. 

In the energy sector, pollution prevention can reduce environmental damages from 
extraction, processing, transport, and combustion of fuels. Pollution prevention ap¬ 
proaches include: 

— increasing efficiency in energy use; 

— substituting environmentally benign fuel sources; and 

— design changes that reduce the demand for energy. 




Index 


Index 

Symbols 

1000 Friends of Oregon 193 

33/50 Program 3, 4, 18, 27, 50, 61, 75, 76, 91, 105, 260 
3M 12,51,172,235,239,240 

A 

Ace Glass Company 175 

activity-based costing 56, 79 

activity-based management 56 

Advanced Technology Program 6 

Affirmative Procurement Reporting System 110 

Agricultural Research Service 96 

agriculture 6, 18, 21, 28, 29, 32, 36, 37, 46, 47, 53, 58, 67, 
85, 88, 90, 91, 94, 96, 133, 135, 152, 153, 158, 170, 
177, 189, 191, 194, 205, 278 

Agriculture in Concert with the Environment 32, 96 

Air Command and Staff College 103 

Air Force 94, 100, 102, 104, 124 

Alabama 132, 136, 141, 143, 149, 152, 263 

Alaska 136, 141, 149, 266 

All Indian Pueblo Council 152, 154 

Allen, David 9, 163, 180, 181 

Allenby, Brad 55, 184, 244 

Alliance for Aquatic Resources Monitoring 182 

Allied Signal 172 

American Institute for Pollution Prevention 10, 62, 172, 201 

American Institute of Chemical Engineers 172, 258, 262 

American Lung Association 198 

American Petroleum Institute 62 

American Textile Manufacturers Institute 64 

Amoco Petroleum 46, 203 

Aristech Chemical 50 

Arizona 30, 31, 134, 136, 141, 148, 149, 168, 176, 212, 265 
Arizona State University 176 
Arkansas 136, 141, 149, 264, 265 
Army 94, 100, 103 

Association of Small Business Development Centers 58 
AT&T 5, 46, 52, 55, 56, 170, 172, 184, 244 
automotive 21, 58, 61, 108, 112, 128, 172, 191, 196, 197, 
212, 229 

Avondale Mills 64 


B 

Bell Laboratories 184 
Bowdoin College 175,176 
Broward County Environmental Code 197 
Browner, Carol M. v, 3, 19, 40 
brownfields 195, 196 
Buckeye Cellulose Corporation 72 
Bulkley, Jonathon W. 9, 163, 180, 184 
Burlington 64 

business development 5, 25, 58, 59, 132, 141, 224 
Business Roundtable 51, 62, 76, 162 
Business-Environmental Learning and Leadership Program 
171 

c 

California 30, 67, 102, 107, 109, 136, 139, 141, 146, 149, 
167, 176, 190, 193, 197, 203, 205, 208, 255, 265, 266 
Campus Ecology 174,175 
Carnegie Mellon University 172 
Center for Hazardous Materials Research 146, 258, 262 
Center for Neighborhood Technology 202, 264 
Center for Waste Reduction and Technologies 172 
Chemical Manufacturers Association 62, 63 
chemical manufacturing/production 33, 48, 146, 204, 205, 
207, 248 

Chemstation, Inc. 38 
Chrysler 172 
Chugachmiut 152 
Church & Dwight 68 
Ciba-Geigy 46, 68 
CIPMA 97 

Citizens for a Better Environment 196 
citrus 71, 72 

Clark Elementary School 166 
Clarkson University 178 

Clean Air Act 23, 40, 58, 99, 117, 119, 127, 192, 209 

Clean Community System 198 

Clean Industries 2000 139, 140 

Clean Texas Star 139 

Clean Water Act 99, 182, 183, 204 


279 


Index 


Clean Water Action 204 

Cleaning Products Program 112 

Climate Wise 3, 13, 27, 50, 201, 251 

Closing the Circle Award 92, 94, 95, 108, 116, 117, 123, 124 

coal mining 33, 146 

Coast Guard 118, 119 

CocaCola 70 

Codey, Lawrence 55 

Colorado 51, 71, 134, 135, 136, 141, 149, 180, 213, 251, 
265 

Common Sense Initiative v, 3, 18, 22, 39, 172, 258 
community risk profile 190,191 
Community Toxic Waste Audit Program 182 
community-based environmental protection 9, 189, 210, 255 
Compliance Assistance Centers 5, 21, 22, 58, 65 
compliance inspections 8, 149, 150, 220 
Comprehensive Procurement Guidelines 95, 109, 121, 123 
Computer Asset Recovery Service 65 

computers 7, 22, 23, 30, 34, 38, 46, 56, 65, 66, 72, 88, 92, 
107, 110, 111, 128, 140, 141, 142, 146, 178, 204, 207, 
208, 240, 259, 271 
Connecticut 146, 192, 262 
Consumer Labeling Initiative 4, 17, 34, 35 
Coors Brewing Company 74 
Cornell University 167 
Council of Great Lakes Governors 30, 65 

D 

Defense Acquisition University 103 
Defense Authorization Act 104 
Defense Programs Design Agencies 105 
Delaware 76, 137, 141, 149, 262 
Deluxe Corporation 73, 74, 75 

Department of Agriculture 6, 12, 18, 28, 32, 85, 88, 91, 94, 
96, 246 

Department of Commerce 6, 85, 97, 134 
Department of Defense 2, 6, 7, 32, 85, 88, 89, 94, 98, 99, 
100, 101, 102, 103, 104, 116, 122, 125, 126 
Department of Energy 6, 7, 13, 27, 73, 74, 80, 85, 88, 91, 
94, 105, 106, 107, 108, 109, 110, 111, 127, 178, 235, 
251, 258 

Department of the Interior 6, 85, 113, 114 
Department of Transportation 7, 12, 85, 94, 117, 118, 119, 
192, 193 


Design for the Environment 3, 17, 18, 28, 56, 64, 180, 239, 
240, 260 

Dickinson College 9, 163, 178, 182, 183 
Digital Electronics 65, 66 
Donlar Corporation 36, 67 
Doolittle, Craig 5, 43, 78 
Doran Textiles 64 

Dow Chemical Company 2, 5, 36, 43, 46, 78, 79, 172, 203, 
204 

Duke University 176 
DuPont 5, 43, 76, 77 

E 

Earth Generation, Inc. 168 
Eastern Michigan University 178 
Echo Bay/Cove Mine 72, 73 
Eco-Industrial Parks 194, 195 
Ecoprint 60 
EcoSys 103, 111 
EE-Link 168, 169 
electric generation facility 60 

electronics 22, 28, 65, 66, 110, 120, 122, 128, 147, 172, 259, 
265 

Emergency Planning and Community Right-to-Know Act. 

See EPCRA 

Encouraging Environmental Excellence 64 
Energy Analysis and Diagnostic Centers 178 
Energy Policy Act 121 
Energy Star Buildings Program 27 

enforcement settlements 8, 22, 136, 141, 148, 149, 150, 152 
Enviro$en$e 24, 32, 64 
Environment and Education 168,169 
environmental accounting 3, 4, 5, 9, 28, 46, 52, 55, 56, 75, 
171, 230 

Environmental Accounting and Reporting System 230 
Environmental ACTION 8, 168 
Environmental Capital Network 30 
Environmental Champion Award 6, 50, 105 
Environmental Council of the States 160 
Environmental Defense Fund 10, 30, 65, 162, 203, 255 

Environmental Education and Training Partnership Program 
169 

Environmental Greenprint 57 


280 


Index 


Environmental Justice through Pollution Prevention 8, 22, 
23, 29, 31, 152, 175, 182, 183, 189, 194, 195, 196, 197, 
205, 206, 257 

Environmental Leadership Program 4, 36, 60, 68 
Environmental Performance Agreements 24, 218, 219 
Environmental Pollution Prevention Project 6, 96, 97 
Environmental Quality Program 98, 99, 104 
Environmental Report Card 57 

Environmental Security Technology Certification Program 104 
Environmental Success Index 203 
Environmental Technology Initiative 35 
Environmental Technology Requirements Strategy 104 
Environmental Youth Awards 167 

environmentally-preferable products 5, 6, 7, 31, 43, 69, 75, 
87, 112, 114, 121, 122, 123, 237 
ENVVEST 101, 102, 125, 126 

EPCRA (Emergency Planning and Community Right-to- 
Know) 33, 34, 92, 113, 114, 117, 144, 182, 201, 260 

EPIC 105, 107, 110 

Epstein, Marc J. 5, 43, 81 

Ervin, Christine 7, 85, 127 

European Roundtable on Cleaner Production 162 

Executive Order 12759 90 

Executive Order 12780 90, 92 

Executive Order 12843 91 

Executive Order 12844 92 

Executive Order 12845 92 

Executive Order 12856 32, 34, 87, 89, 92, 100, 112, 113, 
114, 115, 117, 119 

Executive Order 12873 7, 92, 94, 110, 112, 121, 122, 123 
Executive Order 12902 92 
Executive Order 12969 93, 113 

F 

facility planning 7, 11, 131, 138, 139, 140, 144, 146, 220, 

221, 222 

Farm*A*Syst 177 

Farrell, Andrea 8, 129, 162 

Federal Aviation Administration 112, 119 

Federal Energy Management Program 110 

Federal Environmental Executive 7, 95, 112, 122, 123, 124 

Federal Facilities Enforcement Office 22, 259 

Federal Facilities Tracking System 88 

Federal Highway Administration 118, 119, 120 


Ferland, James 55 
financial assistance 45, 59, 224, 269 
Florida 51, 135, 137, 141, 143, 149, 170, 175, 197, 204, 
212, 256, 263 

Florida Institute of Technology 170 
Florida Memorial College 175 
Food and Drug Administration 18,28 
Ford Motor Corporation 172 
Forest Conservation Program 57 
Forest Service 96 

Forum on State and Tribal Toxics Action 25, 133 
Freeman, Harry 12, 235, 237, 246, 255 
Friedman, Naomi 10, 187, 211 
Frost, Davis 61 
Frost Paint and Oil 61 

G 

Gade, Mary A. 8, 129, 160 
garment cleaning 172 
Genencor 61, 62 

General Motors Corporation 128, 172, 184 
General Services Administration 6, 32, 66, 85, 110, 111, 
112, 113, 122, 123 

George Washington University 9, 175 
Georgia 57, 134, 135, 137, 141, 149, 263 
Gillette 63 

Goldman, Lynn R. 3, 17 

Goodman, Sherri 7, 85, 102, 125 

Government Performance and Results Act 10, 218, 231 

grants 23, 24, 25, 32, 36, 37, 38, 39, 47, 60, 96, 97, 131, 
132, 133, 134, 138, 139, 140, 148, 151, 152, 154, 155, 
156, 165, 179, 189, 195, 196, 197, 198, 210, 229 

Great Lakes 25, 30, 59, 65, 151, 168, 263 

Great Lakes Initiative 151 

Great Printers Project 30, 64, 65, 160, 203 

green accounting 55, 56 

Green Builder Program 199 

Green Business Recognition Program 140 

Green Chemistry Challenge Award 4, 35, 36, 54, 67 

Green Chemistry Program 35 

green cleaning 199 

Green Design Initiative 172 

Green Index 56 

Green Lights 3, 27, 29, 50, 75, 259 


281 


Index 


green procurement 31 
Green Seal 69 
Greer, Linda 52 
Groundwater Guardian 204 

H 

Habitat for Humanity 199 

Hall, Sue 67, 70 

Hammer Award 27, 123 

Hampshire Research Associates 221, 235, 242 

Harrah's Hotel and Casino 71 

Hartford Courant 73 

Harvard Business School 170 

Harvard University 46, 175, 184 

Hawaii 137, 141, 149, 265 

Heiman, Michael 163, 178, 179, 182 

Henkel Company 70 

Holtzapple, Mark 36 

Home Center Institute 57 

Home Depot 52, 56, 57 

I 

ICF Kaiser Hanford Company 106 
Idaho 137, 141, 149, 266 

Illinois 78, 129, 137, 141, 149, 151, 152, 160, 161, 162, 178, 
179, 198, 235, 243, 258, 264 
Imation Enterprises 23 
Indiana 61, 137, 141, 149, 151, 152, 229, 264 
Industrial Ecology 184,244 
Industrial Pollution Prevention Council 62, 76, 162 
Industrial Pollution Prevention Project 45, 47, 63 
Industrial Products, Inc. 170 

INFORM 45, 47, 70, 195, 205, 228, 235, 248, 256, 257 

Institute for Local Self-Reliance 203 

Institute of Advanced Manufacturing Sciences 176 

Integrated Training Area Management 103 

Intel Corporation 23, 30 

Inter-Tribal Council on the Environment 153 

Intermodal Surface Transportation Efficiency Act 118 

Iowa 58, 132, 137, 141, 143, 149, 217, 223, 224, 265 

ISO 14000 35, 89, 121, 146, 159 


J 

Jiminy Cricket's Environmentality Challenge Program 67 
Joint Center for Sustainable Communities 202 

K 

Kansas 105, 107, 108, 112, 137, 141, 149, 265 
Kentucky 25, 137, 141, 143, 148, 149, 263 
Kotas, Gerald 235,237,238,251 
Kwethluk 152 

L 

Latex Paints Pilot Program 112 
Leadership for Excellence Award 175 
Learning to Be Water Wise and Energy Efficient 166 
life cycle analysis 37, 38, 65, 69, 79, 81, 82, 83, 123, 125, 
126, 166, 171, 172, 173, 208, 228 
Ling, Joseph T. 235, 237, 239 
loans 59, 140, 141, 142, 148 
Louisiana 68, 134, 137, 141, 149, 246, 264 
Lucent Technologies 184 

M 

Maine 30, 136, 137, 141, 149, 262 
Malcolm Baldridge National Quality Award 98 
Management Institute for Environment and Business 9, 45, 
47, 170, 171 

Manufacturing Extension Partnership 6, 25, 58, 97, 98, 132, 
136, 137, 138 

Marine Plastic Pollution Research and Control Act 104 
Maritime Administration 120 
Martin Marietta 51, 71 

Maryland 10, 59, 60, 137, 141, 149, 187, 190, 210, 262, 263 
Maryland Waste Coalition 10, 187, 210 
Massachusetts 8, 11, 132, 135, 137, 139, 141, 146, 149, 151, 
170, 177, 217, 220, 222, 223, 224, 225, 232, 257, 262 
materials accounting 11, 12, 33, 162, 208, 220, 226, 227, 
228, 249 
Mayo, Dana 175 
McLean, Charles 29 
McPoland, Fran 7, 85, 122 


282 



Index 


measurement v, 2, 10, 11, 19, 33, 43, 45, 47, 49, 52, 57, 59, 
62, 75, 83, 87, 88, 89, 91, 97, 107, 113, 117, 132, 143, 

147, 148, 151, 158, 159, 161, 170, 171, 189, 197, 199, 

201, 204, 214, 215, 217, 218, 219, 220, 221, 223, 224, 

226, 227, 228, 229, 230, 231, 232, 233, 237, 270, 271, 

272, 273 

Media Association P2 Forum 133 
MERIT 29, 30 
Merrimack College 175 
Merrimack Project 63 
metal finishing 21, 37, 58, 97, 180 

Michigan 9, 72, 78, 134, 137, 141, 146, 149, 163, 168, 170, 
174, 176, 178, 184, 238, 264 
Michigan Technological University 178 
microscale experiments 175, 176 
Miles, Inc. 70, 71 
milk and juice packaging 172 

Minnesota 61, 74, 132, 135, 137, 141, 146, 149, 212, 225, 
264, 265 

Mississippi 137, 141, 149, 263, 264 

Missouri 51, 133, 137, 141, 149, 203, 265 

Mongan, Edwin L. 5, 43, 76 

Monsanto Company 4, 36, 50, 51, 52, 53, 54, 204 

Montana 137, 142, 149, 153, 155, 171, 172, 201, 265 

Montana State University 171, 172 

Montreal Protocol 101,117 

Motorola 73 

Muir, Warren R. 12, 45, 47, 235, 237, 238, 242 

N 

National Academy of Public Administration 40, 244 
National Advisory Council on Environmental Policy 81 
National Aeronautics and Space Administration 6, 85, 88, 

94, 114, 115 

National Association of Community Development Loan 
Funds 197 

National Association of Counties 2, 10, 25, 187, 198, 202, 
211, 256 

National Association of County and City Health Officials 10, 
187, 198, 202, 211, 256 * 

National Association of Physicians for the Environment 10, 
202 

National Audubon Society 168 
National Bicycling and Walking Study 118 


National Consortium for Environmental Education and 
Training 168, 169 

National Energy Foundation 166 
National Environmental Education Act 165 

National Environmental Performance Partnership System 10, 
24, 133, 156, 218, 219, 231 

National Environmental Policy Act 87, 127, 251 
National Institute of Standards and Technology 6, 58, 97, 

132, 136 

National Network for Environmental Management Studies 
165 

National Park Service 6, 32, 114 

National Pollution Prevention Center 170, 172, 176, 184, 

185 

National Pollution Prevention Roundtable 8, 25, 129, 133, 
134, 136, 141, 146, 155, 162, 198, 201, 213, 214, 256 
National Retail Hardware Association 57 
National Risk Management Research Laboratory 38, 172 
National Science Foundation 185 
National Tribal Environmental Council 153 
National Tribal Pollution Prevention Conference 153, 201 
National Wildlife Federation 53, 171, 174, 176, 178, 179, 
180, 202 

Native American 103, 131, 153, 154, 155, 156, 157, 165, 

171, 251 

Natural Resource Conservation Service 96 
Natural Resources Defense Council 10, 196, 203 
Navajo Environmental Protection Agency 154 
Navy 94, 100, 101, 104 
Nebraska 137, 142, 149, 198, 256, 263, 265 
Nevada 71, 137, 141, 142, 150, 265 
New England Environmental Assistance Team 22 
New Hampshire 30, 135, 137, 142, 150, 262 
New Item Program 112 

New Jersey 8, 11, 55, 133, 137, 139, 142, 146, 150, 151, 

175, 192, 204, 212, 217, 221, 227, 228, 249, 262 
New Mexico 137, 142, 150, 152, 154, 264 
New Mexico State University 178 
New York 31, 45, 61, 70, 71, 116, 132, 133, 137, 142, 150, 
167, 171, 176, 184, 192, 205, 212, 248, 255, 256, 257, 
258, 262 

New York University 176 
NEWMOA 133, 197, 262 
newspaper 73 

Niagara Mohawk Power Corporation 168 


283 




Index 


North Carolina 2, 8, 11, 58, 129, 132, 137, 142, 150, 158, 
159, 176, 223, 263, 264 
North Carolina State University 176 
North Dakota 137, 142, 150, 178, 265 
Northeast Business Environmental Network 63 
Northeast Waste Management Official's Association. See 
NEWMOA 

Northwestern University 178, 179 

0 

Occupational Safety and Health Administration 199 
Ocean State Power 60 

Office of Enforcement and Compliance Assurance 21, 22, 30 
Office of Pollution Prevention and Toxics 20, 22, 25, 28, 31, 
33, 35, 36, 52, 54, 62, 133, 180, 228, 260 
Office of Prevention, Pesticides and Toxic Substances 3, 17, 
255 

Office of Research and Development 4, 37, 38, 39 
Ohio 8, 25, 138, 142, 150, 151, 193, 212, 259, 264 
Okefenokee National Wildlife Refuge 113 
Oklahoma 23, 116, 138, 142, 150, 178, 264 
Oklahoma State University 178 
OMB/Watch 204 

Ombudsman/Small Business Technical Assistance Program 
136, 137, 138 

opportunity assessments 100, 107, 114, 116, 118, 139, 140 

Optical Imaging Systems 172 

Oregon 51, 138, 142, 146, 150, 193, 266 

Orum, Paul 10, 187, 205, 207 

ozone-depleting substances 73, 91, 99, 100, 101, 116 

P 

P2GEMS 177 
P2/Finance 28 
P2TECH 176, 177 

Pacific Northwest Pollution Prevention Research Center 176, 
266 

paper manufacturing 146 
Partners for the Environment 3, 26, 47, 50, 51 
Partnership for Environmental Technology 180 
Passamaquoddy Tribe 154 

Pennsylvania 51,70, 134, 138, 142, 146, 150, 178, 182, 183, 
258, 262, 263 


Pepsi Cola Bottling Company 70 
Performance Partnership Grant 24, 156 
permitting 3, 8, 23, 30, 40, 73, 77, 102, 119, 131, 134, 139, 
140, 145, 148, 149, 150, 151, 152, 159, 160, 196, 197, 
208, 210, 212, 233, 256, 258, 271 
Pesticide Environmental Stewardship 3, 18, 28 
petroleum refining 22, 146 
Phillips 66 140 
Poarch Creek Indians 152 
Polaroid Corporation 230 

Pollution Prevention Act v, 1, 19, 24, 33, 39, 48, 58, 76, 87, 
121, 135, 151, 156, 165, 207, 239, 242, 267, 269, 277 

Pollution Prevention Alliance 203 
Pollution Prevention Forum 21 

Pollution Prevention Incentives for States 8, 11, 23, 58, 132, 
133, 138, 139, 143, 152, 153, 154, 229, 260 
Pollution Prevention Information Clearinghouse 35, 46, 59, 
107, 256, 257, 260 

Pollution Prevention Information Tracking System 131, 144 
Pollution Prevention Network 132 
Pollution Prevention Pilot Project 203, 204 

Pollution Prevention Strategy 6, 23, 33, 90, 111, 112, 113, 
114, 115, 117, 135, 151, 229, 243, 277 

Pollution Prevention Through Technology Transfer 36 
Pollution Prevention Trade Association Workgroup 62 
Port Gamble S'Klallam Tribe 154 
Porter, Michael 46 

President's Council on Sustainable Development 41 
Printers National Environmental Assistance Center 65 

printing 21, 22, 28, 30, 31, 37, 49, 58, 60, 63, 64, 65, 66, 68, 
73, 74, 92, 97, 146, 160, 162, 177, 180, 203, 212, 255 
Printing Industries of America 30, 64, 65 
Proctor & Gamble 51 
product stewardship 5, 63, 65, 67, 250 
Project XL v, 3, 18, 29, 30, 55, 125, 161, 210, 230 
Public Service Electric and Gas 5, 52, 54, 55 
Purdue University 176, 264 

R 

Rayonier 204 
Raytheon 63 

RCRA (Resource Conservation and Recovery Act) 11, 40, 

65, 73, 99, 122, 144, 151, 226, 228, 257 


284 



Index 


Recycled Materials Affirmative Procurement Tracking 109, 
110 

Regal Fruit Co-op 72 

regulatory integration 7, 135, 138, 139, 148, 149, 150, 155 
Renew America 202 

Resource Conservation and Recovery Act. See RCRA 
Responsible Care 62, 63 
retailers 5, 53, 57 

Rhode Island 60, 138, 140, 142, 144, 147, 148, 150, 262 

Rice University 176 

Rifkin, Tom 73 

Rimer, Linda Bray 8, 129, 158 

Rockefeller University 190 

Rohm and Haas 36 

Rosso, Mary 10, 187, 210 

Roxbury Community College 197 

RTK NET 34,204,205 

S 

Safe Drinking Water Act 40 

SARA Title III (Superfund Amendments and Reauthorization 
Act) 172,272 
Saturn Corporation 178 
Science Advisory Board 90, 189, 198 
Scientific Certification Systems 69 
Screenprinting and Graphic Imaging Association 64 
Silicon Valley task force 191 
Small Business Administration 58 
Small Business Assistance Programs 25, 136 
Small Business Compliance Assistance Centers 5, 58 
Small Business Development Centers 5, 25, 58, 59, 132, 
136, 224 

Small Business Ombudsman 58 

small businesses 5, 7, 8, 25, 30, 37, 43, 57, 58, 59, 65, 132, 
136, 137, 141, 145, 160, 161, 162, 176, 197, 224, 244 

Solid and Hazardous Waste Education Center 176, 177 

Source Reduction Review Project 3, 20 

South Carolina 108, 138, 142, 150, 263 

South Dakota 138, 142, 150, 265 

Southeast Community Development Corporation 193 

St. Gallen University 46 

State Technical Assistance Program 58, 150 

Statutory Integration 40 

Strategic Environmental Associates 67 


Strategies for Today's Environmental Partnership 62 
Students for Environmental and Ecological Development 179 
Superfund 40, 172, 208, 210, 269, 272, 273, 274 

Superfund Amendments and Reauthorization Act. See SARA 
Title III 

Supplemental Environmental Projects 22, 152 
Sustainable Agriculture Research and Education 6, 32, 96 
sustainable development 38, 41, 53, 57, 76, 79, 127, 153, 
170, 173, 184, 185, 189, 191, 194, 197, 204, 237, 239, 
240, 241, 243, 244, 249 

Sustainable Development Action Strategy 194 
Sustainable Development Award 57 
Synergy CCS 108 

T 

technical assistance 3, 6, 7, 8, 9, 11, 23, 24, 25, 27, 30, 32, 
58, 59, 65, 75, 96, 98, 131, 134, 136, 138, 139, 140, 

141, 142, 143, 145, 146, 150, 152, 154, 155, 156, 160, 

161, 165, 166, 171, 176, 177, 181, 196, 197, 199, 202, 

203, 207, 210, 212, 218, 221, 223, 224, 249, 252, 256, 

258, 260, 263, 264, 266, 269, 270, 271 

Tellus Institute 46, 197, 238 

Tennessee 94, 138, 142, 143, 144, 147, 150, 178, 191, 263, 
264 

Texas 8, 9, 36, 38, 51, 58, 107, 108, 138, 139, 142, 143, 

144, 146, 150, 163, 166, 181, 195, 199, 204, 264, 265 
Texas A&M University 36 
textile 39, 49, 64, 68, 97, 147, 200 
Thomas, David L. 12, 184, 235, 237, 238, 243 
Toxics Release Inventory. See TRI 

toxics use reduction 11, 135, 177, 215, 222, 223, 224, 225, 
232, 257, 262 

Toxics Use Reduction Institute 11, 177, 215, 232, 257, 262 
transportation 7, 10, 12, 49, 57, 58, 63, 85, 90, 94, 117, 118, 
119, 128, 174, 190, 191, 192, 193, 202, 206, 241, 251 
Transportation Acquisition Manual 119 
Transportation Partners Program 193 
TRI (Toxics Release Inventory) v, 4, 6, 10, 12, 17, 18, 27, 

32, 33, 34, 43, 47, 48, 49, 50, 53, 87, 88, 91, 92, 93, 94, 
102, 113, 117, 121, 140, 144, 178, 179, 182, 183, 201, 

204, 205, 207, 208, 226, 227, 228, 248, 249, 260 
Tri-State Geographic Initiative 25 

Tri-State Transportation Campaign 192, 193 
Tribal Environmental Policy Act 197 
tribes 8, 103, 131, 132, 133, 136, 137, 138, 139, 140, 152, 
153, 154, 155, 156, 189, 197, 201, 260 


285 


Index 


Troccoli, Karen 10, 187, 211 
TSCA (Toxic Substances Control Act) 205 
Tufts Environmental Literacy Institute 171 
Tulalip Tribes 197 

Tumer-Fairbank Highway Research Center 118 

u 

U.S. Agency for International Development 6, 85, 96 

U.S. Conference of Mayors 202,214 

U.S. Enrichment Corporation 88, 94 

U.S. Geological Survey 6, 114 

U.S. Postal Service 6, 32, 85, 115, 116, 117, 122, 124 

U.S.-Asia Environmental Partnership 162 

Underwood, Joanna D. 12, 235, 237, 248 

Union Carbide 4, 52, 54 

Unison Institute 204 

United Nations Environment Program 162 
United Solar Systems 172 
University of California 107, 176 
University of Illinois 178 

University of Massachusetts 170, 177, 232, 257, 262 

University of Michigan 9, 163, 170, 174, 176, 184 

University of New Orleans 12, 178, 235, 246 

University of North Carolina 176 

University of North Dakota 178,265 

University of Tennessee 144,178 

University of Texas at Austin 9, 163, 181 

University of Washington 176 

University of Wisconsin 176,177 

Utah 138, 142, 150, 265 

utilities 5, 33, 35, 47, 54, 55, 56, 252, 259, 261 

V 

van der Linde, Claas 46 
Vermont 58, 138, 142, 150, 262 
Virginia 58, 134, 135, 138, 142, 144, 150, 194, 221, 242, 
255, 260, 262 
visioning 190, 191 

voluntary partnerships 26, 29, 50, 138, 139 
voluntary programs 3, 4, 8, 17, 26, 29, 43, 47, 48, 50, 64, 76, 
77, 139 


w 

Walt Disney Company 66, 67 
WAR 38 

Washington 11, 72, 101, 138, 139, 142, 146, 150, 176, 197, 
199, 212, 220, 222, 227, 255, 259, 266 
waste management 8, 39, 68, 69, 87, 108, 109, 113, 114, 

116, 133, 135, 148, 149, 192, 203, 205, 242, 256, 263, 
264, 265, 269 

Waste Management and Research Center 12, 178, 243 

waste minimization 6, 9, 20, 28, 77, 105, 106, 108, 109, 110, 
111, 115, 116, 124, 134, 151, 173, 197, 246, 260, 263, 
265 

Waste Minimization National Plan 28, 77 
Waste Prevention F.I.R.S.T. 151 

waste reduction 7, 23, 37, 38, 55, 60, 61, 64, 66, 90, 100, 
105, 106, 107, 113, 115, 116, 120, 134, 135, 136, 140, 
143, 147, 148, 154, 165, 171, 172, 176, 179, 180, 184, 
199, 202, 210, 223, 230, 231, 242, 246, 255, 258, 259, 
262, 263, 264, 266 

Waste Reduction and Technology Transfer Foundation 136, 
143, 263 

Waste Reduction Assistance Program 143, 147 
WasteWiSe 3, 27, 28, 55, 64, 66, 261 
Water Alliances for Voluntary Efficiency. See WAVE 
WAVE (Water Alliances for Voluntary Efficiency) 3, 29, 50, 
261 

Wellhead Protection Project 198 
Wellman, Inc. 70 

West Virginia 25, 138, 142, 144, 150, 262 
White House 7, 85, 92, 94, 120 
Wilderman, Candie 183 

Wisconsin 58, 138, 142, 150, 162, 176, 177, 264 
Working Group on Community Right-to-Know 10, 187, 205, 
207 

World Resources Institute 46, 170, 171 
Wyoming 138, 142, 150, 265 


286 

































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